Automatic Enrollment Requirements Further Delayed

The Patient Protection and Affordable Care Act requires employers with 200 or more full-time employees to automatically enroll all new full-time employees in the company’s group healthcare plan. Current employees will be automatically re-enrolled and employees will be allowed to opt out. In January 2011, the IRS issued frequently asked questions (FAQs) providing that until implementing regulations are issued, employers are not required to comply with the automatic enrollment requirement. At that time it was expected that automatic enrollment rulemaking would be completed by 2014.


New FAQs (Notice 2012-17) have now been issued by the agencies in response to questions from employers regarding this automatic enrollment requirement. Given the concerns with implementation and developing coordinated guidance, the agencies have now indicated that automatic enrollment guidance won't be ready to take effect by 2014. Thus, until final regulations are issued and become applicable, employers won't be required to comply with the automatic enrollment requirement.


Employers are advised to continue to monitor healthcare reform developments. Should you have questions about this or any aspect of federal health insurance reform, contact your Conner Strong & Buckelew account representative toll free at 1-877-861-3220. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.


This Legislative Update is provided for general informational purposes only and is not intended to be legal advice. Readers are urged to contact an attorney for legal advice or assistance.

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