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IRS Grants Limited Transition Relief to Small-Employer Premium Reimbursement Arrangements
Spencer FaneLink to more items from this source
[Guidance Overview]
Feb. 19, 2015

"Although ALEs with 50 to 99 full-time employees (including full-time equivalents) may rely on a different transition rule to avoid any ACA 'play-or-pay' penalties during 2015, there is no similar relief in Notice 2015-17.... Note that this transition relief is limited not only in duration (i.e., only through June 30, 2015), but also in scope. It applies only to a small employer's reimbursement (or direct payment) of health premiums ... Small employers now have just over four months in which to wind down any impermissible premium-reimbursement arrangement. In its place, they may wish to adopt a plan through a SHOP Marketplace. Although individuals may enroll through a Marketplace during only annual or special enrollment periods, there is no such limitation on an employer's ability to adopt a plan through a SHOP."

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