News & Analysis as of September 18, 2024

Pay or Play

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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 -

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

Locke Lord LLP on 6/12/2015

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

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

Ballard Spahr LLP on 11/6/2014

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...

Mintz - Employment, Labor & Benefits... on 8/12/2014

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

Monthly Benefits Update

Franczek P.C. on 6/3/2014

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

Parker Poe Adams & Bernstein LLP on 5/21/2014

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"?

Foley & Lardner LLP on 4/25/2014

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...

Mintz - Employment, Labor & Benefits... on 4/22/2014

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

Best Best & Krieger LLP on 4/2/2014

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 February....more

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

Mintz - Employment, Labor & Benefits... on 4/1/2014

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

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

Mintz - Employment, Labor & Benefits... on 3/11/2014

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

Winthrop & Weinstine, P.A. on 3/11/2014

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

Sherman & Howard L.L.C. on 3/10/2014

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

Oh, What a Shock! Provisions of the ACA Delayed Again

Obermayer Rebmann Maxwell & Hippel LLP on 3/7/2014

In a move that will not come as a surprise to anyone who has been following the rocky implementation of the Affordable Care Act (“ACA”), the Obama Administration has yet again delayed important provisions of the ACA. In a...more

Final “Play-Or-Pay” Regulations Provide Relief And Much Needed Clarification

Perkins Coie on 3/5/2014

The Affordable Care Act added the so-called “Play-or-Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2015, certain employers, referred to as “applicable large...more

Monthly Benefits Update - February 2014

Franczek P.C. on 3/5/2014

Health & Welfare Plans - Health Care Reform: IRS Issues Final ACA “Pay or Play” Regulations - The IRS issued final regulations regarding the employer shared responsibility provisions under the Affordable Care...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 43: Coordinating the 3-Month Delay under Employer Shared...

Mintz - Employment, Labor & Benefits... on 3/4/2014

So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more

Health Care Reform Update -- February 24, 2014

Mintz - Health Care Viewpoints on 2/25/2014

In This Issue: Implementation of the Affordable Care Act; Other Federal Regulatory Initiatives; Other Congressional and State Initiatives; and Hearings and Mark-Ups Scheduled. Excerpt from Implementation of the...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 44: The Top 10 Changes Made by the Final Treasury Regulations...

Mintz - Employment, Labor & Benefits... on 2/25/2014

In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new...more

Health Care Reform – New Guidance For Employers And Relief For Mid-Size Employers

Akerman LLP - HR Defense on 2/25/2014

Employers in all industries are well aware of the complexities of the Affordable Care Act, and the seemingly constant barrage of guidance that interprets the health care reform requirements that apply to them. We have a...more

The First Pieces of Health Reform's Pay or Play Penalty Puzzle

Winstead PC on 2/21/2014

Early this week the Internal Revenue Service and Department of Treasury (the “IRS”) issued the first piece of the Affordable Care Act (“ACA”) penalty imposition jigsaw puzzle. It then followed up with 46 FAQs on the same...more

Final Regulations On Affordable Care Act's Employer Mandate Issued – Part 1

FordHarrison on 2/20/2014

Executive Summary: Under final regulations issued by the U.S. Treasury Department on February 10, 2014, employers with at least 50 but fewer than 100 employees will not be required to comply with the employer shared...more

New Final Regulations Provide Transition Relief For Employers From The Affordable Care Act's Employer Shared Responsibility...

Laner Muchin, Ltd. on 2/20/2014

On February 10, 2014, the Internal Revenue Service released final regulations pertaining to the Employer Shared Responsibility Mandate (commonly referred to as "Pay or Play") of the Patient Protection and Affordable Care Act...more

IRS “Pay or Play” Final Regulations Delay Compliance Date for Certain Employers, Reduce Penalty Exposure for Others

Foley & Lardner LLP on 2/20/2014

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

Final Regulations Issued Regarding Employer Shared Responsibility Under the ACA

McDermott Will & Emery on 2/19/2014

Recently issued final regulations on the employer pay-or-play rules under the Affordable Care Act (ACA) clarify the requirement that employers provide health coverage to full-time employees and their dependents, or pay a...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 45: Focus on the Transition Rules under Final Treasury/IRS...

Mintz - Employment, Labor & Benefits... on 2/19/2014

The Treasury Department and the IRS last week issued long-awaited final rules implementing the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules. Originally slated to take effect beginning...more

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