"Technically, the [Treasury Department] announcement does not delay the effective date of the employer mandate itself (i.e., the requirement to offer affordable, qualified coverage or pay a penalty).... Although the delay in the assessment of the penalties may effectively result in a postponement of the requirement to offer affordable, qualified coverage, the contours of the July 2 relief cannot be determined until formal guidance is issued ... It is possible, for instance, that the IRS will require employers to make a good faith effort to comply with the shared responsibility rules in 2014 in order to avoid imposition of the penalties."

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