Pub. 3 2013-2014 Issue 2

10 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S FEATURE ARTICLE “The one-year delay for the information reporting and play or pay provisions has no effect on the effective date of application of other ACA provisions.” Health Care Reform “Play or Pay” Delay What It Means for Employers Now A fter hearing complaints from employers about burdensome reporting requirements under the Patient Protection and Affordable Care Act (ACA), on July 2, 2013, the U.S. Department of the Treasury and the White House announced in separate blog posts that the ACA reporting requirement and employer re- sponsibility payment (“play or pay”) provisions have been delayed until 2015. The sentiments of the blog posts were formalized by the IRS on July 9, 2013, in Notice 2013-45. The one-year delay for the information reporting and play or pay provisions does not change the effective date of other ACA provisions. Play or Pay Provision Per Notice 2013-45, beginning in January 2015 (instead of January 2014), applicable large employers with 50 or more full-time equivalent employees that do not provide minimum essen- tial coverage (defined by the Secretary of Health and Human Services) to full-time employees will be required to pay a penalty. The penalty is applicable if any of those employees are certified to the employer as having enrolled in a qualified health plan and have received a premium tax Robert Conner BKD