October 1, 2013 ACA Notice Requirements for Employers
Confusion reigns regarding the Patient Protection and Affordable Care Act ("PPACA") and obligations to provide notices to employees of information regarding the new Health Insurance Market Place ("Exchanges") by no later than October 1, 2013.
WIB has received numerous calls and inquiries concerning the October 1, deadline over the past several days. Understandably, some of the requirements of the PPACA get lost in the myriad of news reports and debates about extending time limits and attacks on program funding.
WIB is therefore publishing an article by Andy DeClercq with links to model notices. Andy is an attorney with Boardman & Clark, LLP - the law firm retained by WIB to assist WIB members.
In the meantime, a couple of key issues include:
Number of Employees: The October 1, 2013 Notice Deadline is not limited to employers with more than 50 employees. The Notice requirement applies to all employers covered by the Fair Labor Standards Act ("FLSA"). The FLSA covers all employers with at least one employee and at least $500,000 annual business revenue.
Employer Coverage: The October 1, 2013 Notice Deadline is applicable whether or not the employer offers any health insurance to its employees. The model notices used will be different for employers offering health plans from those who do not.
Full vs. Part-Time Employees: The Notice requirements are applicable to both full and part-time employees.
New Hires: Employees hired after October 1, 2013, must be provided applicable notices at the time of hire or within 14 days thereafter.
COBRA Notices: Required COBRA notices for employees have been modified to reflect information on the exchanges.
Video of the Week - 11/25
The SHOP Marketplace in Open
News of the Day - 9/18
Fed to Keep Interest Rate at Record Low
The Federal Reserve on Wednesday pledged to keep interest rates near zero for a “considerable time” after its bond purchases likely end next month.
While the central bank continued to shrink its “quantitative easing” program with an eye toward eliminating it in October, officials gave no indication they were prepared to hike interest rates anytime sooner than previously expected, amid lingering concern about the economic recovery.
Some Fed watchers had expected the Fed to scrap the “considerable time” language, seen in the Fed’s June statement, amid a run of solid economic data. But Fed Chairwoman Janet Yellen reaffirmed Wednesday that the Fed thinks the economy could benefit from lower rates for a longer period of time.
“The labor market has yet to fully recover,” she said at a press conference following the Fed meeting. “Economic conditions may for some time warrant keeping the target federal funds rate below levels the committee views as normal over the longer run.”
But at the same time, Yellen took pains to emphasize that investors and the public should not interpret the Fed’s stance as solemn vow, and that any Fed actions will heavily rely on incoming economic information.
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