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Election Day Surprise: Skinny Plans Will Need to Fatten Up
Benefits Bryan Cave Link to more items from this source
[Guidance Overview]
Nov. 4, 2014
"Early this morning, the IRS, in a coordinated effort with the DOL and HHS, issued guidance that basically said that so-called 'skinny' plans won't get employers out of the 'play or pay' penalties. Limited grandfathering is available for so called 'Pre-November 4, 2014' plans. All of this will be finalized in future regulations, but the guidance sets out what the agencies expect the regulations to say.... If you have already entered into a binding written commitment to offer one of these plans or have started enrolling your employees in these plans, as of this election day, then the agencies are expected to give you a pass on the play or pay penalties for 2015."

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