On July 9, 2013, the IRS issued Notice 2013-45 (Notice) delaying the effective date of the Patient Protection and Affordable Care Act (ACA) employer shared responsibility requirements, also known as the "pay or play" rules. These rules will now apply in 2015. Accordingly, employers will not be subject to the penalties for failing to offer coverage to fulltime employees in 2014.
The Notice confirms that proposed rules for the information reporting provisions for selffunded plans and insurers are expected to be published this summer and that information reporting will be optional for 2014. The Notice also reiterates that, because the information reporting is optional for 2014, it is not feasible to determine which employers would owe employer shared responsibility penalties for 2014 and, therefore, no employer sharedresponsibility penalties will be assessed for 2014. 
The Notice also confirms that individuals' eligibility for premium tax credits continues to depend on whether employer sponsored coverage is affordable and provides minimum value. Finally, the Notice reiterates that the transition relief for the information reporting and employer shared responsibility penalties has no effect on the effective date or application of other ACA provisions.