On Jan. 2, the IRS published proposed regulations addressing numerous issues with the Affordable Care Act’s (ACA’s) shared responsibility requirements. These proposed regulations include a special transition rule that provides relief from penalties for non-calendar year plans, also known as fiscal year plans.
The transition relief is provided because it may be difficult for employers with fiscal year plans to comply with the ACA’s shared responsibility rules on Jan. 1, 2014. Those plans would have had to make changes for the 2013 plan year, or make mid-year changes effective Jan. 1, 2014, to be compliant and avoid penalties.
The transition relief includes the following components:
- If employees who are eligible for employer-sponsored coverage under the terms of the plan in effect on Dec. 27, 2012, are offered affordable, minimum value coverage that starts no later than
