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“Play-or-Pay” Mandate Delayed Again for Some Employers

February 10, 2014

By Thomas I. Kramer


Readers of our July 3, 2013 Alert know that the employer “play-or-pay” mandate, which was originally scheduled to take effect January 1, 2014, was postponed until January 1, 2015. On February 10, 2014, the Internal Revenue Service issued final regulations implementing the mandate and postponing the mandate further for some employers.

The final regulations, which may be published in the February 11, 2014 Federal Register, contain a number of important modifications, many of which will be helpful to “applicable large employers” obligated to comply with the play-or-pay mandate. The IRS has issued a Fact Sheet regarding the final regulations.

Although the January 1, 2015 deadline remains in effect for the play-or-pay mandate generally, for employers with at least 50 but fewer than 100 full-time-equivalent employees, the deadline is postponed until January 1, 2016. This does not postpone other aspects of healthcare reform, many of which took effect January 1, 2014.

We will report on the more technical aspects of the final regulations after the full text of the regulations becomes available. In the meantime, please feel free to contact us at any time about healthcare reform or other labor, employment, or benefits issues.