You may have noticed a recent slowdown in Affordable Care Act guidance, and really any other governmental guidance coming out of HHS, DOL and Treasury. This is not by accident. Unofficially, there is a temporary slowdown in guidance until after the election. After the election passes, you should expect a number of key pieces of Affordable Care Act guidance to drop. This would include the employer penalty under 4980H, how to test for minimum value and additional guidance on the reinsurance fees.
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