"[H]ighlights include the following: Clarification that an applicable large employer must offer coverage to 'substantially all' FTEs and their dependent children up to age 26 in order to avoid potential liability for the play or pay penalty.... Clarification that the shared responsibility requirements are generally applied separately to each member of the controlled group.... Expansion of safe harbors for determining whether the employer's health coverage is affordable for purposes of the play and pay penalty.... Special transition relief for non-calendar year plans in existence as of December 27, 2012."

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