The White House announced on July 2, 2013, that it would delay imple­men­ta­tion of the Afford­able Care Act’s report­ing require­ments applic­a­ble to large and mid-sized employ­ers and health insur­ers for one year. As a result, the health insur­ance man­date applic­a­ble to these same employ­ers will not be enforced until 2015. The announce­ment appeared in sep­a­rate blog posts from the White House ( and the Depart­ment of the Trea­sury (

 The Afford­able Care Act (ACA) man­dates that employ­ers with 50 or more full-time equiv­a­lent employ­ees must offer health insur­ance cov­er­age to their employ­ees by Jan­u­ary 1, 2014, or pay fines, referred to as “shared respon­si­bil­i­ty pay­ments.” In addi­tion, the ACA requires that these same employ­ers and health insur­ance providers com­ply with cer­tain report­ing require­ments also by Jan­u­ary 1, 2014. Now these require­ments will not be enforced until Jan­u­ary 1, 2015. 

Pro­posed rules imple­ment­ing these report­ing pro­vi­sions are expect­ed to be pub­lished this sum­mer. In the inter­im, since report­ing require­ments are delayed, the gov­ern­ment can’t read­i­ly deter­mine which employ­ers owe shared respon­si­bil­i­ty pay­ments for not com­ply­ing with the insur­ance man­date, neces­si­tat­ing a delay in the imple­men­ta­tion of that require­ment. Impor­tant to note is that the White House announce­ment indi­cat­ed that employ­ers exceed­ing the min­i­mum health insur­ance man­date may not have to ful­fill some of the more detailed report­ing requirements. 

In an effort to encour­age a smoother tran­si­tion in 2015, once the pro­posed rules are issued, employ­ers are encour­aged to imple­ment pro­ce­dures nec­es­sary to meet the report­ing require­ments, and to use the extra time to adapt their cur­rent health insur­ance offer­ings to com­ply with the ACA insur­ance mandate. 

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