If you sponsor an insured, non-grandfathered group health plan, Christmas has come a little early this year. The IRS has officially delayed the effective date of the impending nondiscrimination requirements for insured plans until after regulations or other administrative guidance can be issued (IRS Notice 2011-1). In addition, the IRS anticipates that any future guidance will not apply until the first plan year beginning some specified period of time after issuance. The nondiscrimination mandate for insured plans, which prohibits plans from discriminating in favor of highly compensated individuals, is part of the federal Patient Protection and Affordable Care Act (PPACA), the health reform law enacted earlier this year. The rules were set to go into effect for calendar year plans on January 1, 2011, but this guidance gives plans some much-needed breathing room. If you have questions about how the nondiscrimination rules could affect your plan, contact Kristine Cienfuegos at Vigilant.
This website presents general information in nontechnical language. This information is not legal advice. Before applying this information to a specific management decision, consult Vigilant or legal counsel.