February 11, 2014 – Alert – Final Employer Shared Responsibility Regulations Release
This afternoon the IRS released final regulations regarding the employer shared responsibility provision (also known as the play or pay requirements) of the Patient Protection and Affordable Care Act. The regulations will be published in the Federal Register on Wednesday, but an advanced copy of the regulations is available here: http://www.ofr.gov/OFRUpload/OFRData/2014-03082_PI.pdf.
We are in the process of reviewing the 227 pages of preamble and regulations and will issue subsequent Alerts once we have had a chance to analyze the impact of the final regulations. However, we wanted to highlight one very significant change from the proposed regulations. The regulations include an additional delay in the play or pay requirements until 2016 for large employees with between 50 and 99 employees. The requirements remain applicable to large employers with 100 or more employees starting in 2015.
Please watch for additional alerts regarding the final regulations. In the meantime, if you have questions about the final regulations, please contact us.