On July 3, 2013, the Department of the Treasury announced its intention to postpone information reporting requirements by employers and other parties that provide health coverage effectively delaying the employer “pay-or-play” mandate.  In summary, large employers would have been required to provide a report on their health care plans and covered employees at the end of 2014.  The delay in the reporting requirement made it impractical for health care exchanges to determine which employers may owe shared responsibility payments (under section 4980H) for 2014 (play-or-pay penalties).

However, proposed regulations have been released and the employer mandate is scheduled to be effective January 1, 2015.  The proposed regulations provide the roadmap for determining whether an employer will be subject to the “pay-or-play” penalty for either not offering health care to full-time employees or not offering affordable health care to full-time employees applicable in 2015.  Employers need to determine which employees must be offered coverage.  We will cover the following areas:

1. Counting full-time equivalent employees
2. Determining full-time employees and variable hour employees for coverage purposes
3. Affordability of coverage requirement (the 9.5% requirement)
4. Potential “play or pay” penalties starting in 2015 under sections 4980H(a) and 4980H(b)

Date:          Tuesday, October 29, 2013
Time:          12:00pm – 1:15 pm

Location:  Holland & Hart
555 Seventeenth Street
Suite 3200
Denver, CO 80202-3979

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