“Play or Pay” Compliance Deadline Extended for Employers

The Patient Protection and Affordable Care Act of 2010’s shared responsibility provision, commonly referred to as “play or pay,” was scheduled to take effect Jan. 1, 2014. But on July 2, the U.S. Treasury announced that the effective date would be delayed one year, to Jan. 1, 2015. IRS guidance will be issued providing more details and perhaps additional changes.

The original provision, in some cases, imposes non-deductible penalties (generally $2,000 per full-time employee) on “large employers” that don’t offer coverage or that provide coverage that is “unaffordable” or that doesn’t provide “minimum value.”  A “large employer” is defined as one with at least 50 full-time employees, or a combination of full-time and part-time employees that’s “equivalent” to at least 50 full-time employees.

The rules are complex, and the new IRS guidance is expected to clarify — and perhaps simplify — them. Please contact us for the latest information and to determine how your company may be affected.