from IMA member Vedder Price PC
One of the 2013 action items for employers under the Patient Protection and Affordable Care Act (PPACA) is the production and distribution of a notice to employees about the health insurance exchanges that will become effective in 2014. Under the statute, these notices were originally required to be distributed by March 1, 2013. However, in January 2013, the U.S. Department of Labor (DOL) delayed this distribution requirement until it had an opportunity to issue further guidance. On May 8, 2013, the DOL issued that guidance in the form of Technical Release 2013-02 and a model notice published on the DOL’s website. The DOL describes the insurance exchanges as “Marketplaces,” a term we will use in this alert.