The Obama Administration does not support an administrative delay of the 2014 employer or individual mandate

From the KTS Health and Welfare Team:

 

For the last two days, I have been presenting at the annual JCEB health and welfare conference, which is an annual gathering of employer health plan professionals and government representatives.  A few key items emerged from this year’s meeting, listed briefly as follows:

 

–          The Obama Administration does not support an administrative delay of the 2014 employer or individual mandate.

–          The employer penalty guidance will be released in early 2013.  Treasury is considering applying the employer penalty to “substantially all” employees, meaning that if an employer misses the mark on a handful of employees, the employer is not penalized on all employees.

–          Additional guidance regarding the reinsurance rule is expected in December.  There is still time to file more comments to exempt EAPs, retirees and expats.  KTS filed comments here http://www.kilpatricktownsend.com/en/Knowledge_Center/Publications/Other_Publications/2012/10/Kilpatrick_Townsend_Health_and_Welfare_Team_Files_HHS_Comments.aspx

–          DOL will issue additional wellness guidance by the end of the year.  It’s unclear if this guidance will implement the 20% to 30% change in 2014 or earlier.

–          HHS will continue additional HIPAA privacy and security audits in 2013.
Mark L. Stember
Kilpatrick Townsend & Stockton LLP
Suite 900 | 607 14th Street, NW | Washington, DC  20005-2018
office 202 508 5802 | cell 202 714 5019 | fax 202 585 0018
mstember@kilpatricktownsend.com | My Profile | vCard

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