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Vedder Thinking | Articles Health Care Reform: Employer Shared Responsibility Requirements Require Action


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This alert discusses two recent regulatory developments under the Patient Protection and Affordable Care Act (PPACA):

  1. The government postponed until late summer or fall of 2013 a deadline (originally March 1, 2013) for providing notices to employees about coverage options available through federal and state exchanges.
  2. The IRS published proposed regulations regarding PPACA’s definition of “full-time employee” and how that definition impacts the employer shared responsibility rules that become effective in 2014.

This alert focuses primarily on the employer responsibility requirements, sometimes referred to as the “play or pay” rules, that begin applying in 2014 and impose significant penalties on employers for noncompliance (potentially as high as $2,000 per full-time employee per year). Significantly, hours worked by employees this year will be used in determining if an employer is subject to the shared responsibility requirements and which of its employees must be offered coverage next year. Accordingly, employers should begin taking steps now to comply.

Learn more about these steps by downloading the alert below.

A significant amount of work needs to be done in the coming months to prepare for 2014, which will usher in dramatic changes in the rules governing employer-sponsored health benefits.

Vedder Price attorneys are actively working with clients to help them formulate compliance strategies that fit their business needs and objectives. For assistance, please contact Thomas G. Hancuch at +1 (312) 609-7824, Philip L. Mowery at +1 (312) 609-7642 or any Vedder Price attorney with whom you work.


Thomas G. Hancuch


Philip L. Mowery