Guidance and Safe Harbors for Large Employers | Plante Moran
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Alert - Health Care Reform Update: New regulations provide much needed guidance and safe harbors for large employers

​The IRS issued proposed regulations relative to the large employer-shared responsibility provisions, sometimes referred to as “play or pay,” of the Patient Protection and Affordable Care Act of 2010 (PPACA).  The regulations further define large employers that are subject to the shared responsibility provisions, outline the requirements of a qualified health plan (QHP), and explain the penalties applicable to large employers that fail to offer a QHP to their full-time employees.

Although the shared responsibility provisions of PPACA are not effective until January 2014, employers will use 2013 to determine whether they are considered a large employer, and therefore subject to the “play or pay” mandate and, if so, to consider possible changes to avoid potential penalties.  Employers who may be exposed to potential penalties will also need to evaluate and balance the potential cost of the penalties versus the cost of offering a QHP to their full-time employees and, where necessary, implement plan changes prior to 2014.

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