Some employers may have rejoiced when IRS Notice 2013-45 delayed until 2015 the implementation of the employer shared-responsibility penalties mandated by the Patient Protection and Affordable Care Act (ACA). Certainly, this delay is a win for employers; however, other healthcare reforms will demand the attention of health plan sponsors before January 1, 2014. Husch Blackwell attorney Scott Behrens recently summarized the requirements, which include a Notice of Exchange Availability, Limits on Overall Cost Sharing and Transitional Reinsurance Fee.
Despite the delay for employer shared-responsibility penalties, other penalties apply for failing to comply with ACA provisions that demand plan sponsor’s attention prior to January 1, 2014. Accordingly, plan sponsors should closely review their plans and make any necessary amendments to ensure compliance and avoid penalties.
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