Q&A with Wayne Pettigrew
Employers should issue notice of
health insurance marketplaces
Q: What is the Oct. 1 deadline that employers must meet under the Patient Protection & Affordable Care Act (PPACA)?
A: Employers both large and small were required to provide a notice to full- and part-time employees regarding new health insurance marketplace coverage options by Oct. 1. The purpose of the notification is to inform employees about the new health insurance exchanges and subsidies that will be available to individuals effective Jan. 1 and to provide information about the employer's current offerings to employees.
Q: Wasn't the employer mandate delayed?
A: Although some portions of the PPACA were delayed until 2015 for employers, this notice requirement remains in effect. Many small employers may assume that they aren't required to provide this notice, but this notice applies to all employers that are required to comply with the Fair Labor Standards Act regardless of the number of employees they have. Only the $100 fine per employee per day for failure to provide the notice has been temporarily waived.
Q: If an employer missed today's deadline, should they go ahead and provide notices?
A: Yes. I believe adhering to the requirements, even belatedly, will demonstrate an employer's good faith in fulfilling its fiduciary responsibilities.