The delay was announced on July 2nd, and the IRS issued formal guidance on July 9th.
Unfortunately, some confused souls have taken this to mean that the entire implementation of the ACA has been delayed. Au contraire! (Yes, now that Kristen’s back from Europe, we’re all speaking French.)
WHAT IT MEANS: Large groups with 50+ full-time employees will not be required to provide minimum essential affordable coverage to employees until 2015. Large groups who do not comply in 2015 will be financially penalized. Initially, the mandate would have required large groups to coverage to be provided by 2014. This “transition relief for 2014” gives large group employers more time to prepare for the impact of this “pay or play” mandate in 2015 and beyond.
WHAT IT DOES NOT MEAN: The decision does not mean that all of Healthcare Reform has been delayed until 2015. There are still numerous changes that go into place starting January 1, 2014, such as:
- Community rating (affects only employers under 50 full-time employees in 2014)
- Prohibition of waiting periods longer than 90 days
- Individual mandate to carry coverage
- Small group and individual Exchanges (opening on 10/1/2013, for coverage starting 1/1/2014)
- Out-of-pocket maximum on coverage must not exceed $6,350 single / $12,700 family, AND must include copays towards that max (this is new for all but HSA plans)
Please see Notice 2013-45 for more information about the official guidance just released.
As always, please This email address is being protected from spambots. You need JavaScript enabled to view it. with any questions you have as you navigate through the maze of Healthcare Reform.
