Employer Mandate Penalties

On July 9th, the IRS issued Notice 2013-45 announcing that certain reporting requirements under the Patient Protection and Affordable Care Act (“PPACA”) would be delayed for one year.  Specifically, Notice 2013-45 states that certain tax Code reporting requirements will not apply for 2014 and, instead, are delayed for one year (presumably meaning that the first reports required to be filed will have to be submitted in January 2016).  In addition, because the information otherwise required to be reported is vital to the IRS’s ability to assess and collect the employer “play or pay” penalties under PPACA, imposition of the penalties are likewise delayed and will not apply until 2015.  Finally, Notice 2013-45 clarifies that additional guidance will be issued later this summer regarding these employer reporting requirements under PPACA.