Employee Benefits and Executive Compensation Advisory: Regulation of "Employee Leasing Companies" under the Fair Share Contribution Requirement of the Massachusetts Health Care Reform Act

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A Conundrum for Staffing Firms, PEOs and Other Three-Party Employment Arrangements

While the DHCFP and the DUA and other state agencies have done yeoman's work issuing the guidance and establishing the administrative systems and IT infrastructure necessary to implement all of the (2006 Massachusetts Health Care Reform) Act's requirements, certain challenges remain. These challenges include the application of the FSC rules to traditional staffing firms, Professional Employer Organizations (PEOs) and other three-party employment arrangements. This Mintz Levin Employee Benefits and Executive Compensation client advisory explains the issues that have arisen in connection with these arrangements.

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