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Final Regulations Regarding Verification of Eligibility for Qualifying Coverage in an Employer-Sponsored Health Plan

The Centers for Medicare & Medicaid Services recently released final rules under the Affordable Care Act that, among other things, set forth the requirements for verifying whether individuals are eligible for a premium tax credit or certain cost-sharing relief upon their enrollment in a qualified health plan through an exchange. Exchanges will generally rely on information provided by enrollees on their applications for coverage regarding whether or not they are eligible for qualifying coverage in an employer-sponsored health plan. Employers are encouraged, but not required, to assist their employees in completing such applications by providing information on whether the employer?ÇÖs health coverage, if any, is ?Ç£affordable?Ç¥ and provides ?Ç£minimum value.?Ç¥ The final rules can be found?áhere.

IRS Notice Regarding 2014 Transition Relief for Affordable Care Act Information Reporting and Play-or-Pay Penalties

On July 9, 2013, the IRS published Notice 2013-45, formalizing the Treasury Department?ÇÖs earlier announcement of transition relief through 2014 for the Affordable Care Act?ÇÖs (the ?Ç£ACA?Ç¥) employer and insurer reporting requirements under Sections 6055 and 6056 of the Internal Revenue Code (?Ç£Information Reporting?Ç¥) and employer play-or-pay penalties. The Notice indicates that publication of proposed rules regarding Information Reporting is expected this summer. Although compliance with the Information Reporting requirements is not required during 2014, employers and other reporting entities are encouraged to voluntarily comply once the proposed rules have been issued. A copy of the Notice is available?áhere.

July 2013