On January 24, 2013, the DOL published Part XI of the FAQs about Affordable Care Act (ACA) Implementation, delaying the March 1, 2013, deadline for employers to send an Exchange Notice.
The DOL provided two reasons for delaying the Exchange Notice. First, the notice will be coordinated with educational efforts by the IRS and HHS on the subject of minimum value. Second, a later deadline will ensure that individuals receive a notice with meaningful information. The new deadline will be in the late summer or early fall of this year. Open enrollment for the Exchange – now known as the Health Insurance Marketplace – begins on October 1, 2013.
The DOL also addressed several pending issues for Health Reimbursement Arrangements (HRAs) related to when they are considered to be integratedwith other coverage. Further guidance will be forthcoming.
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