Starting in 2014, provisions of the Patient Protection and Affordable Care Act become effective known as “Pay or Play” or “Employer Shared Responsibility.” Large employers will be faced with the decision whether to offer...more
As we have written in this space in the past, whether a worker is an employee or an independent contractor can have many consequences. The classification can determine whether the principal is liable for the negligent acts...more
Beginning in 2014, "large employers" may be assessed a penalty for not providing required coverage under the employer shared responsibility mandate of the Affordable Care Act. This does not mean that employers need not worry...more
Beginning in 2014, large employers are subject to one of two “shared responsibility” penalties under the Patient Protection and Affordable Care Act (“ACA”), commonly known as the play or pay penalties. The Internal Revenue...more
Only applicable large employers may be assessed a penalty under the employer shared responsibility mandate of the Affordable Care Act. An applicable large employer is defined by the regulations as one that has employed an...more
In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.” These regulations incorporate the provisions of many previous Notices with...more
On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more
Notice 2012-58 (August 31, 2012) describes a number of safe harbors related to the employer mandate under the Affordable Care Act. In today’s post, I want to focus on the Notice’s safe harbor method for determining the...more
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