An important follow-up on our January article, "A New Year's Snapshot on Health Care Reform: 5 Key Changes Affecting Employers in 2013": As we suspected the Federal Department of Labor (DOL), Health and Human Services (HHS), and the Internal Revenue Service (IRS), working together, just published guidance stating that the mandatory notice obligation that had been scheduled to go into effect on March 1, 2013, has been postponed. They expect that compliance with the mandatory notice rule will likely not be enforced until late summer. This timing coincides with the open enrollment period for state health care exchanges that are still taking shape. DOL also confirmed it is still evaluating whether to provide a model notice or recommended language to be used as a guideline for compliance.
We will continue to keep you apprised of developments that we think may affect your business. Of course, if you have a specific question about any of the requirements included in this article or individual compliance requirements applicable to your business, please consult your legal counsel or qualified tax professional.
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