United States: IRS Notice 2015-17—Employer Payment Plans And The ACA’s Market Reforms
According to recently issued guidance from the Internal Revenue Service (“IRS”), enforcement of the Affordable Care Act’s (“ACA”) market reforms will be delayed for certain small employers that pay for individual health insurance policies for their employees. Notice 2015-17 reiterates that these arrangements constitute group health plans that fail to satisfy applicable ACA market reforms but recognizes that some small employers utilizing these arrangements may need additional time to transition to compliant group health […]