The Department of Labor (DOL) has postponed the deadline for employers to provide their employees with written notice informing them of the existence of state-based health insurance exchanges created by the Affordable Care Act (ACA). The Act originally required employers to provide the notice to current employees beginning March 1, 2013, and each employee at the time of hiring thereafter.
The DOL has now stated that employers will not be required to comply with the notice requirement until the agency has issued regulations implementing the requirement and such regulations become applicable. The DOL intends to coordinate the notice with the Department of Health and Human Service's educational efforts and the Internal Revenue Service's guidance on the ACA's tax provisions. The agency expects that the delay in enforcing the notice requirement will be until "late summer or fall of 2013," which will coordinate with the open enrollment period for the state-based health insurance exchanges. In the meantime, the DOL is also considering providing employers with model language that could be used to satisfy the notice requirement.
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Please contact any of the following Roetzel attorneys for further information:
Karen Adinolfi
330.849.6773 | kadinolfi@ralaw.com
Alan Daniels
407.245.2426 | adaniels@ralaw.com
Paul Jackson
330.849.6657 | pjackson@ralaw.com
Doug Kennedy
614.723.2004 | dkennedy@ralaw.com
Nathan Pangrace
216.615.4825 | npangrace@ralaw.com