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Author: Scarinci Hollenbeck, LLC
Date: June 17, 2013
The Firm
201-896-4100 info@sh-law.comAfter delaying the scheduled implementation of the Notice to Inform Employees of Coverage Options requirement, the Department of Labor recently announced a new compliance date of October 1, 2013 for these new obligations from the PPACA. It also released additional guidance and a model notice.
Changes made to the Fair Labor Standards Act (FLSA) pursuant to the PPACA require an applicable employer to provide each employee at the time of hiring, a written notice:
The DOL’s latest guidance highlights that all employers covered under the FLSA must provide a notice of coverage options to each employee, regardless of plan enrollment status (if applicable) or of part-time or full-time status. The notice to inform employees of coverage options must include information regarding the existence of a new Marketplace (this term replaces the term “Exchange”) as well as contact information and description of the services provided by a Marketplace.
As far as the new deadlines, employers are required to provide the notice to each new employee at the time of hiring beginning October 1, 2013. With respect to employees who are current employees before October 1, 2013, employers are also required to provide the notice not later than October 1, 2013.
There is one model for employers who do not offer a health plan and another model for employers who offer a health plan or some or all employees.
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