Roadmap To Compliance: Navigating The Employer Shared Responsibility Rules

Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new "pay or play" rules (also called the shared responsibility rules) that will apply to employers' group health plans beginning 2014 under the Patient Protection and Affordable Care Act of 2010.

Beginning in 2014, certain employers may be subject to an excise tax if any full-time employee is eligible for a premium tax credit or cost-sharing reduction with respect to his or her purchase of coverage on the new health insurance exchanges and either (i) the employer fails to offer minimum essential coverage to its employees (and the employee's dependents), or (ii) the employer offers minimum essential coverage to its employees (and the employee's dependents) but such coverage is unaffordable or does not meet the minimum value requirements.