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Employee Benefits Law Update
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John McMorrow
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January 25, 2013

The Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments) just released new guidance regarding implementation of various provisions of the Affordable Care Act.  The guidance is in the form of Frequently Asked Questions about Affordable Care Act Implementation Part XI (FAQ XI), which cover some important health care reform issues, including a delay in the employer Exchange Notice requirement, application of the annual limit restrictions to HRAs, and the circumstances under which fixed indemnity coverage constitutes excepted benefits. Look for detailed coverage of these latest FAQs.


Of particular note, FAQ XI indicates that the Department of Labor has delayed the March 1, 2013 effective date for employers to provide notice of coverage options available through Exchanges.  According to FAQ XI, the Department of Labor expects that the new effective date will take effect in late summer or early fall of 2013 in coordination with open enrollment for Exchanges.  Further guidance will be issued and a model notice is being considered by DOL.  We will continue to monitor and update you on these changes.

Click here for the link to the FAQ XI


For more information contact:

John P. McMorrow

t: 508.929.1612





Labor, Employment & Employee Benefits Group


Mirick O'Connell

100 Front Street

Worcester, MA  01608

t 508.791.8500

f 508.791.8502


1800 West Park Drive, Suite 400

Westborough, MA  01581

t 508.898.1501

f 508.898.1502


Mirick O'Connell is a full-service law firm with offices in Worcester, Westborough and Boston, Massachusetts.  The Firm's principal practice groups include Business; Creditors' Rights, Bankruptcy and Reorganization; Elder Law; Family Law and Divorce; Intellectual Property; Labor, Employment and Employee Benefits; Land Use and Environmental Law; Litigation; Personal Injury; Public and Municipal Law; and Trusts and Estates.
This client alert is intended to inform you of developments in the law and to provide information of general interest.   It is not intended to constitute legal advice regarding a client's specific legal issues and should not be relied upon as such.  This client alert may be considered advertising under the rules of the Massachusetts Supreme Judicial Court.