Document Archive > Delayed

At 4:00 PM Eastern Standard Time today, the Department of Treasury (IRS) issued Notice 2011-1 delaying implementation of the non-discrimination rules for insured plans (required under Section 2716 of the Public Health Service Act as promulgated under the new Health Care Reform laws).

In brief, the Notice states, that because regulatory guidance is essential to the operation of these new rules, the IRS, Departments of Labor (DOL) and Health and Human Services (HHS) collectively have determined that compliance should not be required until the first day of the plan year beginning after such guidance has been issued.

We will provide additional comments on the contents of this Notice as time permits.

IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of ( i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.