The Treasury Department announced on July 2 that the Obama Administration has decided to delay the effective date of the information reporting requirements and the employer mandate, also known as the "Play or Pay" rules, that apply to large employers under the provisions of the Affordable Care Act (ACA). These rules, which were to go into effect as of January 1, 2014, will not apply until 2015.

According to the Treasury announcement, the Administration is particularly concerned with the complexity of the informational reporting requirements imposed on insurance companies and employers under the ACA.  It wants to simplify those reporting requirements and, in the meantime, the employer mandate and related penalty provisions (the "shared responsibility" payments) will be put on hold. The announced delay does not affect employees' access to premium credits nor any other provision of the ACA. Finally, the announcement indicates that formal guidance regarding the one-year delay will be issued within the week. Proposed rules simplifying the reporting requirements are expected later this summer.

We will continue to monitor the developments and keep our clients and prospects informed. Employers may still want to start analyzing their health plans so that adjustments can be made over the next year, as full implementation is expected to begin in 2015.

Following is a link to the announcement from the Treasury Department: http://www.treasury.gov/connect/blog/Pages/Continuing-to-Implement-the-ACA-in-a-Careful-Thoughtful-Manner-.aspx

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