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IRS Issues Final Regs on Pay-or-Play, Including Relief for Multiemployer Health Plans
ERISA Lawyer Blog Link to more items from this source
[Guidance Overview]
Feb. 24, 2014
"The penalty is imposed on an employer. A multiemployer health plan pays for its participants' benefits with employer contributions that are required to be made under collective bargaining agreements. But the plan is not the employer on which a 'pay-or-play' penalty could be imposed. So why would a multiemployer health plan care about 'pay-or-play'?"

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