Beware: ACA Transition Relief Ending June 30
After that, financial penalties will apply!
Last February, the IRS issued a notice alerting employers with fewer than 50 full-time or full-time equivalent employees that penalties for impermissible premium reimbursements for individual health insurance policies would be delayed until after June 30, 2015.
Such arrangements could subject an employer to a $100/day excise tax per applicable employee (which is $36,500 per year, per employee) under section 4980D of the Internal Revenue Code, originally effective as of Jan. 1, 2015.
The IRS concluded that employers that had been offering health coverage through noncompliant employer payment arrangements that could trigger this penalty might need additional time (as might many employees) to obtain alternate group coverage or implement other approaches to purchasing and paying for insurance to avoid liability under the ACA.
The transition relief from penalties ends June 30, 2015, as explained in IRS Notice 2015-17. If you’re not sure about whether you may be exposed, check with your insurance agent or CBIA (860.244.1900).
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