January 3, 2013 – Play or Pay Proposed Regulations Issued
Happy New Year!
In keeping with its practice of issuing guidance right before a holiday, late on December 28th the IRS released proposed regulations and a set of FAQs (available here) regarding the Affordable Care Act’s play or pay requirements. The proposed regulations were officially published in the Federal Register yesterday and are available here .
In the 144-page document, some questions are answered, some questions are not answered, and new questions have “bubbled” up (in honor of New Year’s Day). A few important topics addressed include:
- Application to teachers (9 month employees)
- Application to controlled groups
- Employers with fiscal year plans
- Temporary staffing agencies
As we make our way through the guidance, we will keep you updated.
If you have any questions, please contact us.
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The information contained in this ALERT is intended for general information purposes only and does not constitute legal advice relative to a specific situation.