As we ring in 2013, employers should be focused on measuring their obligations under the shared responsibilities provisions of PPACA. On Dec. 28, we got two additional pieces of guidance that tie together various prior notices relating to minimum essential coverage, measuring employees and potential liabilities. The IRS has given us the proposed rule on Shared Responsibilities for Employer Regarding Health Coverage and some questions and answers to frequently asked questions.

What the IRS has provided is consistent with prior advice, but it does clarify some key points. Not the least of which is that while these rules do not go into effect until January 1, 2014, employers should be using the 2013 plan year as their basis for collecting information relevant to their compliance obligation. 

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