The federal health reform law, the Patient Protection and Affordable Care Act (PPACA) imposes an obligation on employers to notify all employees by March 1, 2013, about the existence of the state-based insurance exchanges required by the PPACA, and about the value of any employment-based health insurance offerings. The notice is intended to allow employees to make informed choices about whether to enroll in employment-based coverage, or seek coverage through an exchange.
Yet many states are lagging well behind in the effort to establish an exchange, and federal authorities have–to date–issued no guidance regarding the form and content of the required notice.
As a result, we understand federal authorities expect to delay the notice, and require employers to issue the notice with open enrollment materials, for open enrollments beginning in the autumn. If history is any guide, the obligation might apply for open enrollments beginning on or after September 23, 2013, but we should know shortly precisely what the federal authorities have in mind.