July 10, 2013
The employer shared responsibility “play or pay” requirement provides that employers with 50 or more full-time or full-time equivalent employees must offer affordable, minimum value coverage to most full-time (30+ hours/week) employees or pay a penalty. That requirement was scheduled to take effect Jan. 1, 2014, although employers that met transition requirements could delay compliance until the start of the 2014 plan year. In addition, extensive reporting was expected to be required regarding the coverage offered to employees. Now we believe (1) the reporting requirements will be provided later this summer; (2) reporting will not be required until 2015; and (3) since it is not possible to assess or enforce employer penalties without reporting, the play or pay mandate also will be delayed until 2015. 1. What’s Been Delayed The play or pay provision requires employers with 50 or more employees to do the following to avoid penalties: Offer minimum essential coverage to 95 percent of full-time employees Offer minimum […]
