Yesterday, as part of a set of just released Q&As by the Department of Labor, it was announced that the requirement for all employers to provide a notice to all employees informing them of the existence of health care exchanges by March 1, 2013, has been delayed. The DOL has indicated that the notice requirement will be implemented at some point in late summer or early fall 2013.
Additional information required in that notice includes details about the exchange, the subsidies that may be available to employees under certain conditions, and the consequences of opting to purchase coverage at the exchange rather than under an employer plan.
The DOL is considering providing a model notice with generic language for employers to use to create their own for their employees. It is expected that they will do so as they have done with so many other required notices.
Their reasoning for this delay is based upon the fact that the provision of this notice should be coordinated with HHS’s educational efforts regarding exchanges still to come. In addition, the DOL feels that employers need more time to be fully compliant with this requirement and that employees receive this information at a time that is more meaningful – closer to exchange effective dates.