Kilpatrick Townsend

Additional Auto Enroll and Employer Penalty Guidance

This morning the IRS issued Notice 2012-17.  The Notice provides information on questions from employers regarding the provisions of the Affordable Care Act governing automatic enrollment, the employer penalty, and the 90-day limitation on waiting periods. The Notice also outlines various approaches that the agencies are considering proposing in future regulations or other guidance.  Our team will be preparing and analysis of the Notice for distribution next week. The Notice can be found at the following link: