"Implementation of Nondiscrimination Rules Delayed for Insured Health Plans"

On December 22, 2010, the Internal Revenue Service ("IRS") issued Notice 2011-1 (the "Notice") in which it announced that insured health plans will not be required to comply with the nondiscrimination requirements under the Affordable Care Act until regulations or other administrative guidance has been issued by the IRS.  These nondiscrimination requirements originally were effective with respect to insured health plans (other than for grandfathered arrangements) for plan years beginning on or after September 23, 2010.

This Stroock Special Bulletin looks at the Notice and its implications for insured health plans.