Proposed regulations issued by the Internal Revenue Service on December 28, 2012 provide some relief to large employers subject to the employer-sponsored coverage mandate under health care reform. The employer mandate is described in detail in our prior alert that can be accessed at the following link: Don’t Play and Also Pay: Navigating the Employer-Sponsored Health Coverage Mandate. Although issued as proposed regulations, employers may rely on these rules pending the issuance of final regulations or other applicable guidance. Below are highlights of some of the key changes to the employer mandate incorporated in the proposed regulations.
Key Changes Relating to the Implementation of the No Coverage Penalty
In the event that an employer becomes subject to the no coverage penalty, the employer is generally required to pay a monthly penalty of $166.67 (adjusted for inflation) multiplied by its total number of full-time employees (excluding the first 30). The new guidance reduces this potential burden in two key ways.
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