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Affordable Care Act – Upcoming Deadlines

With news stories nearly every day about delays and changes to Healthcare Reform, employers may be unsure which provisions are still scheduled to go into effect in 2014. Here are some upcoming deadlines for employers already offering coverage to their employeesOn September 23, 2013, the new HIPAA/HITECH regulations take effect. Employers should review and update HIPAA policies and procedures including privacy notices and evaluation of business associate relationships and underlying agreements to ensure compliance.

By October 1, 2013, employers must provide workers with information about the health insurance marketplaces, which open for enrollment October 1. All employers must distribute this notice to their employees.

January 1, 2014 is an important date. Cost-sharing limits such as the application of co-payments to out-of-pocket maximums take effect. In addition, the “Individual Mandate” takes effect. Employers should become educated about this change and prepare strategies to address the questions that are likely to arise from employees.

Gay marriage impact. The Supreme Court’s Defense of Marriage Act (DOMA) ruling and subsequent IRS announcement on August 29 modified the treatment of gay married employees for health benefits. Employers should review policies to ensure compliance, especially in payroll where health care benefits for married couples have been historically taxed differently than those for same sex couples.

Although the “Employer Mandate” has been postponed to 2015, employers should continue to prepare by reviewing health plans and planning for 2014 and 2015 to manage the effect of Healthcare Reform on their businesses.

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