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Another Affordable Care Act Delay.

On February 10, 2014, the IRS and the Treasury Department issued their final play-or-pay regulations for employers. These regulations contained a few additional delays that will affect employers for 2015:

  • For employers with 100 or more employees, these regulations contain a phase-in of the play-or-pay requirements. During 2015, these large employers will only be required to provide coverage to 70% of employees, and the 95% requirement won’t apply until 2016.
  • For employers with 50 to 99 employees, the penalties are again suspended for 2015, and these employers have until 2016 to offer any coverage in order to avoid the penalties. In order to qualify for this relief, employers cannot reduce their workforce below 100 solely in order to qualify, and they cannot eliminate or materially reduce any existing coverage. Additionally, they will still be required to report on their workers and coverage during 2015.
  • For employers with fewer than 50 employees, they continue to be exempt from the requirement to provide coverage and from the requirement to report coverage in any year.

In addition, many of the transitional reliefs offered in the original proposed regulations have been renewed for 2015 (such as the additional delay for non-calendar year plans, shortened measurement periods for the initial year, and a hiatus on the dependent coverage requirement for plans that are taking steps for such coverage to be effective in 2016). The IRS has also announced that they intend to issue additional regulations regarding the employer reporting requirements, and these regulations are expected to substantially streamline the reporting requirements for 2015 and beyond.

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