The Internal Revenue Service (IRS) recently issued much-anticipated guidance regarding the application of the employer-sponsored health coverage mandate (often called the “play or pay rules” under health care reform). If a nonprofit employer has 50 or more full-time equivalent employees, the employer needs to carefully consider its approach to the new mandate. Planning for these rules should begin as soon as possible. While the employer coverage mandate itself does not apply until 2014, it may be necessary to begin tracking the hours of employees as soon as October 2012 in order to facilitate compliance.

The Play or Pay Rules Generally -

The employer-sponsored health coverage mandate is designed to require “applicable large employers”1 either to provide employees with adequate and affordable health coverage or to require those employers to pay certain penalties for their failure to do so. Specifically, penalties are triggered if...

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