Delayed Effective Date for Nondiscrimination Rules in Fully-InsuredGroup Health PlansThis supplements Issue14 of our Health Care Reform Management Alert Series, which addressed thenew
nondiscrimination requirements under the Patient Protection and AffordableCare Act (PPACA). As stated in Issue 14, PPACA prohibits fully-insuredplans that have lost grandfathered status from
discriminating in favor of highlycompensated individuals (HCIs) in benefits or eligibility. This provisionwas to become effective for non-grandfathered plans for plan years beginning onor after
September 23, 2010. On December 22, the Internal Revenue Servicereleased Notice 2011-1, which delayed the effective date for the newnondiscrimination requirement.ReadFull AlertDecember 23,
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LLP and should not be construed as legal advice or a legal opinionon any specific facts or circumstances. The contents are intended for generalinformation purposes only, and you are urged to consult a
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be used by any taxpayer for the purpose of avoidingtax penalties that may be imposed on the taxpayer. (The foregoing legend hasbeen affixed pursuant to U.S. Treasury Regulations governing tax
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