'Pay or Play' Requirements Delayed Until 2015

Employers subject to the ‘pay or play’ requirements under Health Care Reform–generally those with at least 50 full-time employees, including full-time equivalents–will not face penalties (also known as employer shared responsibility payments) for 2014.

According to formal guidance released by the IRS, the ‘pay or play’ provisions will be fully effective for 2015 and employers are encouraged to maintain or expand health coverage in 2014 in preparation for compliance. The delay is a result of transition relief being provided for 2014 with respect to certain employer and insurer reporting requirements which are necessary for the IRS to determine whether a penalty may be due.

The delay does not affect the application or effective dates of other Health Care Reform provisions, including the individual shared responsibility requirements scheduled to take effect on January 1, 2014.

Our Summary by Year provides information on other upcoming changes under Health Care Reform.