Health Care Reform -- Recent Legislative Developments and Guidance on Grandfather Rules and New W-2 Reporting Rules
The Obama administration continues to move forward on implementing the Patient Protection and Affordable Care Act of 2010, as amended (the "Health Care Reform Act"), as it has recently issued additional guidance on the grandfather rules for group health plans and the new Form W-2 rules for reporting the cost of employee group health coverage. Of note, the guidance reaffirms that the W-2 reporting of group health coverage costs will not be required until 2012, which means that any such reporting for 2011 will remain optional. The guidance also provides some important clarification on the grandfather rules. On a separate note, legislation repealing the employer "free choice" voucher requirements (which were to go into effect in 2014) has just been enacted.
