Delay in Implementation of Potential
Employer Penalties Under ACA
Janemarie Mulvey
Specialist in Health Care Financing
Bernadette Fernandez
Specialist in Health Care Financing
Annie L. Mach
Analyst in Health Care Financing
July 16, 2013
Congressional Research Service
7-5700
www.crs.gov
R43150
CRS Report for Congress
Pr
epared for Members and Committees of Congress

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Delay in Implementation of Potential Employer Penalties Under ACA

Summary
The Patient Protection and Affordable Care Act (ACA, P.L. 111-148), as amended, attempts to
increase access to health insurance coverage, expands federal private health insurance market
requirements, and requires the creation of health insurance exchanges to provide certain
individuals and small employers with access to insurance. To ensure that employers continue to
provide some degree of coverage, ACA includes a “shared responsibility” provision. This
provision does not explicitly mandate that an employer offer employees health insurance; instead,
ACA imposes penalties on “large” employers if at least one of their full-time employees obtains a
premium credit through the newly established exchange. A companion provision to the employer
requirements is the ACA requirement for most individuals to maintain health insurance coverage
(“individual mandate”) or pay a penalty, with exceptions. These provisions are effective in 2014
according to the ACA statute.
ACA requires the Internal Revenue Service (IRS) to coordinate various information reporting
requirements. Specifically, this information will be used for determining whether
• employer coverage exists and, if it does, whether it is adequate and affordable for
purposes of the employer shared responsibility payments; and
• individuals have an offer of minimum essential coverage for purposes of the
individual mandate, as well as eligibility for premium credits in the newly
established exchanges.
On July 2, 2013, the Obama Administration announced that it is going to delay, until 2015,
enforcement and associated reporting requirements relating to potential employer penalties under
ACA. On July 11, 2013, the IRS released Notice 2013-45, which provided more detailed
information on this transitional relief. According to the IRS notice, this transition relief will
provide additional time for input from employers and other reporting entities in an effort to
simplify information reporting consistent with effective implementation of the law.
This delay may have implications for an individual’s health insurance coverage and eligibility for
tax assistance provided through the exchanges. One potential impact of a delay in the
enforcement of potential employer penalties may be a lower than projected number of “large”
employers offering health insurance coverage. This may result in a larger than projected increase
in the number of workers eligible for premium tax credits in the exchanges in 2014 and an
increase in the number of uninsured. However, while measurement of the magnitude of this effect
is beyond the scope of this paper, one recent study found that a delay may not have a significant
effect on the employer-sponsored health insurance coverage. The Congressional Budget Office
(CBO) and the Joint Committee on Taxation (JCT) have not yet completed an analysis of the
impact that the Administration’s announcement and other recently issued final rules will have on
spending and revenues under current law.
On July 11, 2013, The House of Representatives introduced H.R. 2667: Authority for Mandate
Delay Act, which would delay for one year certain reporting requirements as well as penalties for
certain large employers. CBO and JCT’s cost estimate of H.R. 2667 on July 16 reported that
enacting H.R. 2667 would not affect direct spending or revenues because the bill essentially
codifies the Administration’s recent announcement. Therefore, according to CBO, pay-as-you-go
procedures do not apply.
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Delay in Implementation of Potential Employer Penalties Under ACA


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Delay in Implementation of Potential Employer Penalties Under ACA

Contents
Introduction ...................................................................................................................................... 1
Background ...................................................................................................................................... 1
Reporting Requirements Under ACA ........................................................................................ 2
IRS Notice on Transition Relief ................................................................................................ 3
Implications for Premium Credit Eligibility and Individual Mandate ............................................. 7
Eligibility for Premium Tax Credits in the Exchanges .............................................................. 7
Individual Penalty Payments ..................................................................................................... 8
H.R. 2667: Authority for Mandate Delay Act .................................................................................. 9

Tables
Table 1. Reporting Requirements in ACA Relating to Private Health Insurance Coverage ............ 4

Contacts
Author Contact Information........................................................................................................... 10

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Delay in Implementation of Potential Employer Penalties Under ACA

Introduction
The Patient Protection and Affordable Care Act (ACA, P.L. 111-148), as amended, attempts to
increase access to health insurance coverage, expands federal private health insurance market
requirements, and requires the creation of health insurance exchanges to provide certain
individuals and small employers with access to insurance. To ensure that employers continue to
provide some degree of coverage, ACA includes a “shared responsibility” provision. This
provision does not explicitly mandate that an employer offer employees health insurance; instead,
ACA imposes penalties on “large” employers if at least one of their full-time employees obtains a
premium credit through the newly established exchange. A companion provision to the employer
requirements is the ACA requirement for most individuals to maintain health insurance coverage
(“individual mandate”) or pay a penalty, with exceptions. These provisions are effective in 2014
according to the ACA statute.
On July 2, 2013, the Obama Administration announced that it is going to delay, until 2015,
enforcement and associated reporting requirements relating to potential employer penalties under
ACA.1 On July 11, 2013, the IRS released Notice 2013-45 which provided more detailed
information on this decision.2
This delay may have implications for the individual mandate and eligibility for tax assistance
provided through the exchanges. It also may have some impact with respect to federal spending
and revenues.3 This report summarizes some of these issues; however, it does not attempt to
identify all possible implications of this delay. This report does not address whether the Obama
Administration has legal authority to delay implementation of ACA reporting requirements and
enforcement of employer penalty.4
Background
ACA includes a number of provisions intended to expand and/or facilitate the purchase of health
insurance coverage.5 These include new federal tax credits for certain low-income individuals to
purchase insurance through the newly established exchanges.6 Prior to the reporting requirements
and employer penalty delay, CBO projected that premium credits would increase federal spending
by $28 billion in FY2014 and by $55 billion in FY2015.7

1 See http://www.whitehouse.gov/blog/2013/07/02/we-re-listening-businesses-about-health-care-law.
2 IRS Notice can be found at http://www.irs.gov/pub/irs-drop/n-13-45.PDF.
3 The Congressional Budget Office and the Joint Committee on Taxation have not yet completed an analysis of the
impact that the Administration’s announcement and other recently issued final rules will have on spending and
revenues under current law.
4 For a discussion on the legal authority, see http://crs.gov/LegalSidebar/details.aspx?ProdId=582.
5 There are a number of CRS reports that provide greater detail on ACA that can be found at http://www.crs.gov/pages/
subissue.aspx?cliid=3746&parentid=13&preview=False. CRS reports relating to private health insurance provisions
will be also identified throughout this memorandum.
6 See CRS Report R41137, Health Insurance Premium Credits in the Patient Protection and Affordable Care Act
(ACA).
7Congressional Budget Office February 2013 Estimate of the Budgetary Effects of the Insurance Coverage Provisions
(continued...)
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In addition, ACA includes potential tax penalties for large employers (those with 50 or more full-
time equivalent employees) who do not share responsibility in the provision of health insurance
coverage. Specifically, in certain circumstances, large employers who do not provide adequate or
affordable coverage may potentially pay a penalty if at least one of their full-time workers enrolls
in an exchange and receives a premium credit.8 Prior to the delay, CBO projected that the
employer penalties would increase federal revenue between $5 and $10 billion in 2014.9
Finally, most individuals will be required to maintain minimum essential coverage (MEC),10
which includes eligible employer coverage, individual coverage, and federal programs such as
Medicare and Medicaid, among others. Individuals who do not maintain MEC for themselves and
their dependents, and who are not exempt from the individual mandate, will be required to pay a
penalty for noncompliance.11 Prior to the delay, CBO projected that the penalty payments by
individuals would equal $3 billion in FY2014 and $5 billion in FY2015.12
Implementation of these provisions (premium credits, employer requirements, and individual
mandate) requires employers, insurance companies, and others to report information related to the
availability and cost of health coverage, among other issues. Coordination of such information
across public and private entities is critical given the interaction of these provisions with each
other.
Reporting Requirements Under ACA
ACA requires the Internal Revenue Service (IRS) to coordinate various information reporting
requirements. Specifically, ACA enacts Internal Revenue Code (IRC) Sections 6055 and 6056 to
provide this information (see Table 1), which will be used for determining whether:
• employer coverage exists and, if it does, whether it is adequate and affordable for
purposes of the employer shared responsibility payments; and
• individuals have an offer of minimum essential coverage for purposes of the
individual mandate, as well as eligibility for premium credits in the newly
established exchanges.

(...continued)
Contained in the Affordable Care Act, http://www.cbo.gov/sites/default/files/cbofiles/attachments/
43900_ACAInsuranceCoverageEffects.pdf.
8 For a discussion of “adequate” and “affordable” coverage see CRS Report R41159, Potential Employer Penalties
Under the Patient Protection and Affordable Care Act (ACA).
9 This range is because CBO cost estimates are reflected in fiscal year, while the penalty payments are in calendar year.
Thus CBO projected that employer penalty payments increase revenues by $5 billion in fiscal year 2014 (October
2013-September 2014) and by $10 billion in fiscal year 2015 (October 2014 to September 2015). CBO, February,
2013.
10 Minimum essential coverage includes (1) coverage under a specified government-sponsored program, (2) coverage
under an eligible employer sponsored plan, (3) coverage under a health plan offered in the individual market within a
State, (4) coverage under a grandfathered health plan, and (5) other coverage recognized by the Secretary of HHS that
meets the qualifications outlined in 45 CFR §156.604.
11 See CRS Report R41331, Individual Mandate and Related Information Requirements under ACA.
12 Congressional Budget Office February 2013 Estimate of the Budgetary Effects of the Insurance Coverage Provisions
Contained in the Affordable Care Act.
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Under these provisions, certain entities are required to file annual returns to the IRS reporting
information for each individual for whom minimum essential coverage is provided. The entities
include health insurance issuers, sponsors of self-insured health plans, government agencies that
administer government-sponsored health insurance programs, and other entities that provide
minimum essential coverage.
The law further states that all information returns reporting MEC are to contain (1) the name,
address, and taxpayer identification number of the primary insured and each other individual
covered under the policy or plan; (2) the dates each individual was covered under minimum
essential coverage during the calendar year; and (3) in the case of health insurance coverage,
whether the coverage is a qualified health plan offered through exchange, and the amount of any
advance payment of the premium tax credit and any cost-sharing reduction.
For purposes of MEC through an employer’s health plans, information returns also should include
the name, address, and employer identification number of the employer maintaining the plan, the
portion of the premium paid by the employer, and any other information that the Secretary (of
Treasury) may require for administering the small business tax credit (Sect. 45R).13
The law also directs the entity filing an information return reporting MEC to furnish a written
statement to each individual listed on the return that shows the information for that individual that
must be reported to the IRS.
IRS Notice on Transition Relief
On July 11, 2013, the IRS released Notice 2013-45 which provided greater detail on transition
relief for 2014 regarding information reporting requirements for the employer shared
responsibility provisions.14 According to the notice, this transition relief will provide additional
time for input from employers and other reporting entities in an effort to simplify information
reporting consistent with effective implementation of the law.
The transition relief is for the information reporting requirements described above (i.e., IRC
Sections 6055 and 6056) as well as a delay in the employer share responsibility provisions (IRC
Section 4980H) (see Table 1). According to the notice:
This transition relief will provide additional time for input from employers and other
reporting entities in an effort to simplify information reporting consistent with effective
implementation of the law. This transition relief also is intended to provide employers,
insurers, and other providers of minimum essential coverage time to adapt their health
coverage and reporting systems. Both the information reporting [requirements] and the
Employer Shared Responsibility Provisions will be fully effective for 2015. In preparation for
that, once the information reporting rules have been issued, employers and other reporting
entities are encouraged to voluntarily comply with the information reporting provisions for
2014. This transition relief through 2014 for the information reporting [requirements] and

13 The small business tax credit in 2014 is only available if small businesses participate in the Small Business Health
Option Exchange and only applies to businesses that meet income and size requirements. See CRS Report R41158,
Summary of Small Business Health Insurance Tax Credit Under the Patient Protection and Affordable Care Act (ACA).
14 The IRS notice can be found at http://www.irs.gov/pub/irs-drop/n-13-45.PDF.
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Employer Shared Responsibility Provisions has no effect on the effective date or application
of other Affordable Care Act provisions.15
The notice also stated that IRS will issue proposed rules on these reporting requirements later this
year. Once issued, employer, insurers, and other reporting entities are encouraged to voluntarily
comply with these information reporting provisions for 2014 in preparation for full application of
the provisions in 2015.
Table 1. Reporting Requirements in ACA Relating to Private Health
Insurance Coverage
IRS Notices
ACA
and
Statute
IRC Section
ACA Provision Description
Regulations
Sect. 1502 6055(a),
Requires certain entities to file
Notice 2012-
6724(d)
annual returns to the IRS reporting
32 requesting
information for each individual for
comments
whom minimum essential coverage
is provided. The entities include:
Proposed IRS
every health insurance issuer,
regulations
sponsor of self-insured health plan,
forthcoming
government agency that
administers government-sponsored
health insurance programs and
other entities that provide
minimum essential coverage.
Sect.
Provides that all information
Notice 2012-
6055(b)(1)
returns reporting minimum
32 requesting
essential coverage are to contain:
comments
1) the name, address, and taxpayer
identification number of the
Proposed IRS
primary insured and each other
regulations
individual covered under the policy
forthcoming
or plan, (2) the dates each
individual was covered under
minimum essential coverage during
the calendar year, (3) in the case of
health insurance coverage, whether
the coverage is a qualified health
plan offered through exchange, the
amount (if any) advance payment of
the premium tax credit and any
cost-sharing reduction.

15 Internal Revenue Code, Notice 2013-45, July 11, 2013, p. 1.
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Delay in Implementation of Potential Employer Penalties Under ACA

IRS Notices
ACA
and
Statute
IRC Section
ACA Provision Description
Regulations
Sect.
Provides that information returns
Notice 2012-
6055(b)(2)
for minimum essential coverage
32 requesting
through an employer’s group health comments
plan also include the name, address
and employer identification number Proposed IRS
of the employer maintaining the
regulations
plan, the portion of the premium
forthcoming
paid by the employer, and any
other information that the
Secretary (of Treasury) may
require for administering the small
business tax credit (Sect. 45R).
Sect.
Directs the entity filing an
Notice 2012-
6055(c)(1)
information return reporting
32 requesting
minimum essential coverage to
comments
furnish a written statement to each
individual listed on the return that
Proposed IRS
shows the information that must be regulations
reported to the IRS.
forthcoming
Sect. 1513
4980H
Imposes a penalty on large
Proposed
employers (50+ FTEs) who (1) do
regulation
not offer coverage for all of their
issued on
full-time employees, offer
December 28,
unaffordable minimum essential
2011.
coverage, or offer plans with high
out-of-pocket costs and (2) have at
least one full-time employee
certified as having purchased health
insurance through an exchange and
was eligible for a tax credit or
subsidy.
Sect. 1514
6056(a),
Directs every applicable “large”
Notice 2012-
6724(d)
employer (50 or more full-time
33
equivalent employees within the
meaning of Sect. 4980H(c)(2)
Proposed IRS
employer shared responsibility
regulations
provision) during a calendar year to forthcoming
file a return with the service that

reports the terms and conditions of
the health care coverage provided
to the employer’s full-time
employees.
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IRS Notices
ACA
and
Statute
IRC Section
ACA Provision Description
Regulations

6056(b)
Provides that the return used to
Notice 2012-
satisfy the requirements under this
33
section must include:
Proposed IRS
•
the name and employer
regulations
identification number of
forthcoming
the applicable large
employer,
•
the date the return is
filed,
•
certification as to
whether the applicable
large employer offers its
full-time employees (and
their dependents) the
opportunity to enroll in
minimum essential
coverage under an eligible
employer-sponsored plan,
•
the number of full-time
employees for each
month of the calendar
year,
•
for each full-time
employee, the name,
address, and taxpayer
identification number,
and the months the full-
time employee (and any
dependents) were
covered by employer-
sponsored coverage.
•
other such information as
may be required by the
Secretary of the
Treasury.
Sect. 9002
6051
Requires employers to disclose the
Notice 2012-9
value of the employee’s health
insurance coverage sponsored by
Employers
the employer on the annual Form
with less than
W-2.
250 W-2
employees are
not required
to submit
information
until further
guidance is
issued.
Source: Compiled by the Congressional Research Service.
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Implications for Premium Credit Eligibility and
Individual Mandate
A delay in the enforcement and implementation of potential employer penalties in 2014 may have
an impact on the number of individuals eligible for premium credits and the payments of the
individual penalty under the individual mandate requirements. These changes also may have an
impact on federal spending and revenue associated with the employer penalty, individual
mandate, and premium credits. The following section discusses these issues in greater detail.
Eligibility for Premium Tax Credits in the Exchanges
ACA authorized new federal tax credits to go towards covering premiums for health insurance
offered through the newly established exchanges (marketplaces) beginning in 2014. These
premium credits will be available to individuals and families who have household incomes
between 100% and 400% of the federal poverty level (FPL), and do not have access to MEC
elsewhere. In addition, an individual may have an offer of MEC from an employer, but if that
coverage is not adequate or affordable, that individual could qualify for premium tax credits.16 In
addition to premium credits, ACA also establishes subsidies to reduce cost-sharing expenses.
One potential impact of a delay in the enforcement of potential employer penalties under ACA in
2014 may be a lower than projected number of “large” employers offering health insurance
coverage. This may result in a larger than projected increase in the number of workers eligible for
premium tax credits in the exchanges in 2014. The magnitude of this effect is beyond the scope of
this paper. A recent study by the Urban Institute found that the delay in the enforcement of the
employer penalty has almost no effect on overall coverage under the ACA or the distribution of
that coverage across public and private sources.17 CBO and JCT have not yet completed an
analysis of the impact that the Administration’s July 2, 2013, announcement and other recently
issued final rules will have on spending and revenues under current law. That analysis will be
released soon.
Individuals filing for a premium tax credit face the same requirements with respect to accuracy as
when they file their annual taxes. Under current law, individuals who knowingly provide false
information are subject to penalties and there is no statute of limitations for fraudulent claims. In
addition, there are a number of other information reports and processes available to the IRS and
the exchanges to validate an individual’s income and whether an individual has access to MEC
and the nature of that coverage.
Under ACA, the amount received in premium credits is based on the prior year’s income tax
returns. These amounts are reconciled in the next year when individuals file tax returns for the
actual year in which they received a premium credit. If a tax filing unit’s income changes, and the
filer should have received a higher credit amount, this additional credit would be included in their

16 Coverage by employers must be adequate (meets or exceeds 60% actuarial value) and affordable (employee
premiums cannot exceed 9.5% of household income). For more information about these criteria see CRS Report
R41159, Potential Employer Penalties Under the Patient Protection and Affordable Care Act (ACA).
17 Linda Blumberg, John Holohan, and Matthew Buettgens, It’s No Contest: The ACA’s Employer Mandate Has Far
Less Effect on Coverage and Costs Than the Individual Mandate, Urban Institute, July 2013.
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tax refund for the year. On the other hand, any excess amount that was overpaid in premium
credits would have to be repaid to the federal government as a tax payment, with some limits on
repayment based on income.
In addition, a recent final regulation issued by HHS provides guidance to exchanges in
determining eligibility for advance payments of the premium tax credits and cost-sharing
reductions in the absence of information about the availability of employer-sponsored insurance.18
Under this guidance, prior to January 1, 2015, an exchange may accept an applicant’s attestation
regarding enrollment in an eligible employer-sponsored plan and eligibility for qualifying
coverage in an eligible employer plan for the benefit year for which coverage is requested without
further verification.19 While HHS indicates that this is an option for state-based exchanges, HHS
indicates that federally-facilitated exchanges (including partnership exchanges) will not rely on
an applicant’s attestation and instead adhere to the verification procedures outlined in
regulations.20
Even with a delay in reporting requirements (as outlined in IRS Notice 2013-45), there are a
number of other information reports available to assist IRS in confirming whether someone has
MEC when applying for premium tax credits in a state-based exchange. For example, a proxy for
MEC from an employer may be available from individual’s W-2 forms, as enacted under Sect.
9002 of ACA and described in Table 1 above. ACA requires employers to disclose the employer’s
contribution towards an employee’s health insurance coverage on the employee’s W-2 form. The
W-2 information available after April 15, 2014 would be based on tax returns filed for CY 2013
which would require some reconciliation of information in later years. This information, however,
would not identify or report whether employers are offering coverage that is adequate or
affordable, nor is it available consistently for workers at firms less than 250 workers.21 In these
cases, there is nothing preventing the state exchanges from contacting an individual’s employer to
determine more information about the health insurance coverage provided.
Finally, employers are encouraged to voluntarily comply with the reporting requirements in 2014.
For those employers that voluntarily comply, this will provide additional information to IRS
regarding the existence and nature of an individual’s health insurance coverage if available.
Individual Penalty Payments
Beginning in 2014, ACA includes a requirement for most individuals to have health insurance or
potentially pay a penalty for noncompliance. Individuals will be required to maintain minimum
essential coverage for themselves and their dependents. Some individuals will be exempt from the
mandate or the penalty, while others may be given financial assistance to help them pay for the
cost of health insurance and, in some cases, cost-sharing.
If the delay in enforcement of the employer penalty reduces the offer of employer-sponsored
coverage, this may lead to an increase in the number of uninsured who may be potentially subject

18 78 Federal Register 42160, July 15, 2013.
19 Ibid.
20 Ibid.
21 IRS Notice 2012-9 provided transitional relief to firms who employ less than 250 workers in that they are not subject
to the reporting requirement until further guidance is issued. Unless further guidance is issued, individuals who work at
firms with less than 250 workers would not have the value of his/her health insurance coverage reported on their W-2.
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to the individual mandate’s penalty. As noted earlier, however, the magnitude of this effect is
outside the scope of this report.22
Similar to the discussion above with respect to premium credit eligibility, determining the
existence of MEC for purposes of the individual mandate may require reliance on other
information available to the IRS. In this case, because there is a financial penalty for
noncompliance, individuals will have an incentive to approach their employers to certify that they
have MEC.
While information regarding the existence of MEC would be available for employers who
voluntarily comply with the reporting requirements in 2014, there may also be other sources of
this information available to tax filers. For example, as noted above, a proxy for minimum
essential coverage from employers may be available on an individual’s W-2 form as enacted
under Sect. 9002 of ACA and described in Table 1 above. Since the individual mandate payments
are determined when an individual files taxes, the W-2 information would be available at that
time for workers at firms with more than 250 employees (see discussion under premium credits
above).
H.R. 2667: Authority for Mandate Delay Act
On July 11, 2013 the House of Representatives introduced H.R. 2667: Authority for Mandate
Delay Act. The bill would delay for one year certain reporting requirements as well as penalties
for certain large employers that do not offer “affordable” health insurance coverage to their
employees (as affordability is defined in the Affordable Care Act, P.L. 111-148 and the health
care provisions of P.L. 111-152).
CBO and JCT’s cost estimate of H.R. 2667 on July 16 reported that enacting H.R. 2667 would
not affect direct spending or revenues because the bill essentially codifies the Administration’s
recent announcement. Therefore, pay-as-you-go procedures do not apply.23 This cost estimate is
done under the following assumptions and methodology. As a general rule, CBO evaluates
legislation being considered in the House or Senate relative to the agency’s baseline
projections. New information about the implementation of legislation―such as an agency
issuing a final rule or making an official announcement clearly defining an intended
Administration action like the Department of the Treasury’s announcement on July 2, 2013―is
incorporated in CBO’s next regular baseline update. However, following longstanding
procedures, CBO also immediately takes that information into account when analyzing
legislation being considered by the Congress.




22 Linda Blumberg, John Holohan, and Matthew Buettgens, It’s No Contest: The ACA’s Employer Mandate Has Far
Less Effect on Coverage and Costs Than the Individual Mandate, Urban Institute, July 2013.
23 See http://www.cbo.gov/sites/default/files/cbofiles/attachments/hr2667.pdf.
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Delay in Implementation of Potential Employer Penalties Under ACA


Author Contact Information

Janemarie Mulvey
Annie L. Mach
Specialist in Health Care Financing
Analyst in Health Care Financing
jmulvey@crs.loc.gov, 7-6928
amach@crs.loc.gov, 7-7825
Bernadette Fernandez

Specialist in Health Care Financing
bfernandez@crs.loc.gov, 7-0322


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