Health Care Alert - Government Agencies Release Additional Guidance on Minimum Essential Coverage, Minimum Value and Summary of Benefits and Coverage
August 19, 2013
by Eva N. Merz and Kevin J. Hogan
As discussed in our March 20, 2013 Legal Alert – Health Care Reform’s Large Employer Play or Pay Penalties: A Checklist for Employers, large employers will be subject to a penalty tax if they either: (1) fail to offer “minimum essential coverage” to all full-time employees, (and their dependents); or (2) offer employer-sponsored coverage to all full-time employees but the coverage is either not “affordable” or does not provide “minimum value.” These penalties, commonly referred to as the “large employer play or pay penalties,” were originally scheduled to take effect on January 1, 2014. However, as discussed in our July 3, 2013 Legal Alert – Treasury Announces Large Employer Play or Pay Penalties Will Be Delayed For One Year, on July 2, 2013, the Treasury Department announced that large employers will have an additional year to comply with the employer shared responsibility penalty provisions.
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