Health Care Reform

Due to the Treasury and IRS release of the "Employer Shared Responsibility for Employers Regarding Health Coverage" Final Rule published in the Federal Register on Feb. 12, 2014, this web page is currently under construction and is being revised to reflect recent revisions to the employer mandate requirements. For a summary of what changed, please ask your advisor for a copy of our white paper.

Employer Mandate


The Patient Protection and Affordable Care Act (PPACA) requires that by Jan. 1, 2015, applicable large employers must decide whether to "pay or play" in the realm of employer-sponsored group health plans.

An employer may be required to "pay" a penalty for failing to offer a group health plan, providing unaffordable coverage or providing coverage that provides less than the minimum value requirement. The penalty would be triggered if one of the employer's full-time employees obtained coverage through a health insurance exchange and qualified for a premium tax subsidy.

Alternatively, an employer will not pay a penalty if it decides to "play" by offering affordable, minimum value group health coverage for its employees (and their dependents). PPACA refers to the "pay or play" requirement as "shared responsibility," and employers need to understand the possible impact on plan designs, contribution strategies and workforce planning.

This section includes information on the employer mandate requirement.

Recent Developments

On July 9, 2013, the IRS issued Notice 2013-45, which provides a one-year delay for employers subject to PPACA's employer mandate and information reporting requirements, initially scheduled to be implemented in 2014.

It is important to note that the notice does not affect other PPACA provisions (or their effective dates), including the exchange notice, Form W-2 reporting, the summary of benefits and coverage (SBC) requirement, insurance market reforms for small groups, PPACA's fees and taxes, the individual mandate and the establishment of the exchanges.

Additional Resources

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