ALERT: IRS delays pay or play mandate until 2015

Employers rarely hear great news from the IRS, but they really came through this time. The IRS announced yesterday that implementation of the employer shared responsibility mandate (also known as the “pay or play” mandate) will be delayed until 2015. (The mandate requires that employers of 50 or more full-time employees provide substantially all full-time employees and their dependents the opportunity to enroll in affordable, employer-sponsored coverage that offers minimum value, or else pay penalties to the IRS.) This delay gives employers some breathing room as they try to develop benefit strategies for a post-reform world. With any luck, a year from now employers will have significantly more guidance and clarity over how to best navigate the shared responsibility mandate. The IRS plans to issue, this summer, proposed regulations on some informational reporting obligations of employers and group health plans, which appear to be optional, but encouraged in 2014. Yesterday’s development does not affect individuals’ eligibility for, or the availability of premium tax credits to buy coverage through the new health insurance exchanges, nor does it affect any other provision of the Affordable Care Act (ACA). Vigilant will update our members as further developments occur. Questions? Contact Kristine Bingman at Vigilant.