As mentioned in our Health Care blog posts from last week, employers will now have an additional year – until 2015 – to begin complying with the mandatory reporting obligations and play or pay provisions of PPACA.

Yesterday, the IRS released formal guidance regarding this transitional relief. Our Client Alert addressing this guidance can be accessed here.

Despite the transitional relief, it appears that employers may still need to perform the “minimum value” analysis (i.e., the 60% test) for their group health plans for the 2014 plan year.