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The Internal Revenue Service (“IRS”) and the Department of Labor (“DOL”) continue to issue guidance to employers regarding those provisions of the Patient Protection and Affordable Care Act of 2010 (“ACA”) which are scheduled to become effective for 2013 and 2014. This recent guidance includes Proposed Treasury Regulations (the "Proposed Regulations”) interpreting Section 4980H of the Internal Revenue Code (“IRC”) issued by the IRS and the latest edition of Frequently Asked Questions (“FAQs”) issued by the DOL concerning the implementation of ACA. Listed below are four recent developments of note from the Proposed Regulations and FAQs that warrant special attention by employers, as well as some recent statistics released by Gallup which hint at some troubling health care trends.
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