Although enforcement of the Affordable Care Act (the “ACA”) play-or-pay rules has been delayed until 2015, the new online health insurance marketplace (better known as the “exchange”) will be up and running by January 1, 2014. By the start of the exchange’s open-enrollment period on October 1, 2013, nearly all employers must provide a notice to their current employees about the availability of insurance through the exchange and how exchange coverage relates to the employer’s health plan (if any).

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