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Schiff Hardin LLP July 3, 2013
Schiff Hardin Labor and Employment Alert

Deadline For the Employer "Pay or Play" Mandates Under Health Care Reform Extended Until 2015

Late yesterday, the Assistant Secretary for Tax Policy posted an informal "Treasury Notes" blog announcing that the Administration would extend the deadline to 2015 for certain mandatory employer reporting requirements and for the employer "pay or play" penalties under the federal health care reform act.

Those reporting requirements included information designed to help the government determine whether employers with 50 or more full-time equivalent employees might be subject to a penalty under the employer shared responsibility provisions (a.k.a "pay or play" rules) if the employer provided no coverage or coverage that might be deemed unaffordable.

As a result of postponing the effective date of the reporting requirements, the Treasury Department's blog also announced that it would not be assessing any penalties against large employers under the "pay or play" rules until 2015. This announcement means that employers with 50 or more such employees will have additional time to consider how the "pay or play" rules apply in the context of their business model and more time to consider how to comply with those rules.

The Administration expects to release formal guidance regarding this transitional relief within the next week.

It also expects to release proposed regulations relating to the PPACA employer and insurer reporting requirements later this summer.

We will provide additional information relating to this decision as it arises.