Patient Protection and Affordable Care Act of 2010

Updated November 15, 2022

On October 11, 2022, the IRS and the Treasury Department released final regulations relating to premium tax credit eligibility for families, along with companion cafeteria plan guidance in Notice 2022-41.[1]  The final regulations are expected to extend eligibility for premium tax credits to some dependents who were previously ineligible for

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.

Recognizing that expatriate group health plans may find it impossible, or nearly impossible, to comply with all of the relevant provisions of the Patient Protection and Affordable Care Act of 2010 (PPACA), the U.S. Labor Department, the U.S. Department of Health and Human Services (HHS) and the U.S. Treasury Department have recently released a joint response to a Frequently Asked Question (FAQ)providing temporary transitional relief to plan sponsors of certain insured expatriate health plans from complying with some of PPACA’s provisions. Last year, the Departments gave sponsors of expatriate group health plans a one-year enforcement reprieve from the summary of benefits and coverage requirement.