Employer Mandates Patient Protection and Affordable Care Act (PPACA) Pay or Play

Employer Mandates is a term commonly used to describe employer insurance obligations under the Affordable Care Act. Under the Affordable Care Act, employers with 50 or more employees are required to provide... more +
Employer Mandates is a term commonly used to describe employer insurance obligations under the Affordable Care Act. Under the Affordable Care Act, employers with 50 or more employees are required to provide minimum essential insurance coverage to their employees or else pay statutory penalties. The concept of an employer mandate is not unique to the Affordable Care Act; many EU countries have their own versions with different and/or expanded employer obligations.  less -
News & Analysis as of

King v. Burwell – Will the Supreme Court Tip the ACA Dominos? Part 1

The health care industry has been closely watching four cases challenging whether federal subsidies could be used to reduce costs to consumers for health insurance purchased on an Affordable Care Act (ACA) Exchange in a state...more

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

ACA Issues for Employers to Stay Aware of in 2015

With the Affordable Care Act's Employer Mandate (Pay-or-Play penalties) now officially in effect, employers with 50 or more full-time or full-time-equivalent employees should have already made all significant changes to their...more

The Affordable Care Act and Staffing: One Size Does Not Fit All

Since its enactment in 2010, the Affordable Care Act (ACA) has generated debate and questions about the law's impact on third-party staffing arrangements. With the effective date of the ACA's "pay-or-play" employer mandate...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 3: Group Health Plan, Cafeteria Plan and Health FSA...

As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more

The Affordable Care Act Part Two – Preparing for 2015

This is the second of a three part series on the Affordable Care Act (“ACA” or “Act”), commonly known as “ObamaCare.” This post discusses the Employer Mandate, which takes effect January 1, 2015, and certain reporting...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 5: Health and Human Services (HHS) Wastes No Time Issuing...

Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more

Feds Tighten the Belt on "Skinny Plans" and Other ACA Workarounds

On January 1, 2015, employers with 100 or more "full-time equivalents" will be subject to the "Pay or Play" regulations under the Affordable Care Act ("ACA"). Over the past few years, many consultants have sought to identify...more

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 20: 9.5% ? 9.56% (And Why It Matters to Applicable Large...

While employers sometimes view the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules in isolation, they don’t operate that way. Instead, they exist side-by-side with other provisions of the Act. In...more

Affordable Care Act Update: Final Regulations Assist Employers With Identifying Full-Time Employees and Reporting Requirements

Earlier this year, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). We issued a Client...more

Your Company Is a ‘Large Employer’ Under the Affordable Care Act—Now What? Requirements for Coverage and Potential Penalties

The Affordable Care Act (the ACA or the Act) requires ‘‘large employers’’ (90 DLR I-1, 5/9/14) with 50 or more full-time employees to offer health insurance coverage to their eligible employees and their dependents or face...more

Monthly Benefits Update

Health & Welfare Plans - July 1 Deadline to Begin Measuring Employee Hours for ACA Employer Mandate/“Pay or Play” - As we have discussed in many previous alerts, the Affordable Care Act’s employer shared...more

Health Care Reform: Beware of Litigation Risks

As almost all employers know, one of the many requirements of health care reform is the so-called employer mandate. The employer mandate generally provides that large employers who fail to offer their full-time employees...more

IRS' Final Employer Shared Responsibility Rules: Who is an "Applicable Large Employer"?

Earlier this year, the IRS issued final regulations that provide additional guidance on the employer shared responsibility rules (also called the “pay or play” rules) that will generally apply to employers’ group health plans...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 36: Hacking the Affordable Care Act’s $100/Day Penalties for...

Particularly with the issuance of final regulations under the Affordable Care Act’s employer shared responsibility rules, employers have been concerned—justifiably—with the pay-or-play penalties. ...more

Play-or-Pay Reprieve for Some Employers

Certain employers may be eligible for a delay in implementing the Affordable Care Act’s employer-shared responsibility mandate, also known as the play-or-pay rules, according to the final rules that were released in...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 39: Common Law Employees and Offers of Coverage on Behalf of...

Distinguishing employees who are full-time from those who are not takes up a good deal of real estate in final regulations published in the Federal Register on February 12 implementing the Act’s employer shared responsibility...more

Are You Susceptible To The Employer Mandate? Diagnose Yourself

Effective January 1, 2015, you could come down with tax penalties under the employer shared responsibility rules of the Affordable Care Act (ACA) if you fail to offer health care coverage to your full-time employees and their...more

Prepare for the employer mandate of the Affordable Care Act

Effective January 1, 2015, you could face tax penalties under the employer shared responsibility rules of the Affordable Care Act (ACA) if you fail to offer health care coverage to your full-time employees and their...more

Finally! IRS Provides Final Play-Or-Pay Guidance

On February 11, 2014, the IRS released final regulations implementing the employer shared responsibility provisions of the Affordable Care Act, also known as the “employer mandate” and “play-or-pay” requirement. In this...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 42: Treasury Department and IRS Issue Final Reporting Rules...

On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...more

Final Rules Issued on Information Reporting for Employers and Insurers Under the ACA

Today, the U.S. Department of the Treasury and the Internal Revenue Service published Final Rules to implement the information reporting provisions for insurers and certain employers under the Affordable Care Act ("ACA"),...more

Final Regulations Clarify Requirements Under Pay or Play Mandate and Extend Transition Relief for Some Employers

On February 10, 2014, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). The final regulations...more

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