January 3, 2013 – Play or Pay Proposed Regulations Issued

Alerts

January 3, 2013 – Play or Pay Proposed Regulations Issued

Happy New Year!

In keeping with its practice of issuing guidance right before a holiday, late on December 28th the IRS released proposed regulations and a set of FAQs (available here) regarding the Affordable Care Act’s play or pay requirements.  The proposed regulations were officially published in the Federal Register yesterday and are available here

In the 144-page document, some questions are answered, some questions are not answered, and new questions have “bubbled” up (in honor of New Year’s Day).  A few important topics addressed include:

  • Application to teachers (9 month employees)
  • Application to controlled groups
  • Employers with fiscal year plans
  • Temporary staffing agencies

As we make our way through the guidance, we will keep you updated.

If you have any questions, please contact us.

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The information contained in this ALERT is intended for general information purposes only and does not constitute legal advice relative to a specific situation.