Several lawsuits have been filed that challenge the availability of insurance subsidies in states that did not establish their own Exchanges. On July 22, 2014, two federal appeals courts issued inconsistent rulings on the availability of subsidies in states with federally-facilitated exchanges (FFEs). The attached Health Care Reform Compliance Bulletin provides an overview of the court decisions and the potential impact on employers.

HCR Federal Courts Issue Conflicting Rulings on Subsidies in Federal Exchanges