AugustReport - page 11

August 2013 CBA REPORT
l
11
feature article
Employers should carefully review
their health plan eligibility provisions
to determine whether their plan ex-
cludes any class of “children” and, if so,
whether eligibility should be extended
to those children. Otherwise, and un-
less additional guidance is issued before
employers make their 2014 plan eligi-
bility decisions, employers will need to
carefully consider the risks when deter-
mining which persons will be eligible for
coverage.
Wilcoxon is a partner inThompson Hine LLP’s
Employee Benefits and Executive Compensation
group and advises employers on the legal requirements
applicable to group health plans.
After submission of this article, the Obama
administration announced that the pay-or-play rules
will not be enforced until 2015. Accordingly, employers
will now have until 2015 to decide whether and how to
change their eligibility provisions in order to avoid the
penalty.
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