Full-Time Employees

News & Analysis as of

Staffing Firms, Educational Organizations, and Breaks-in-Service under the Affordable Care Act Employer Shared Responsibility...

In Q&A format, recently issued Notice 2015-87 addresses a number of pressing issues that have arisen under the Affordable Care Act (ACA), including that law’s employer shared responsibility rules, information reporting...more

FAQs Regarding The ACA's Employer Reporting Requirements And Delay Of Reporting Requirements (Part 2 Of 2)

A few weeks ago, we provided the most Frequently Asked Questions regarding the employer reporting requirements under The Patient Protection and Affordable Care Act (the "ACA"), which are generally effective beginning January...more

Staffing agency workers and ACA offers of coverage

The final regulations on the Affordable Care Act’s (ACA) “pay or play” rules were released on Feb. 10, 2014. Under the rules, there are potential penalties imposed on large employers that do not offer substantially all...more

New York City Commuter Benefits Law (NYCCBL) Makes Changes For Employers With a Workforce On the Go (Compliance Required by July...

This month a new law requiring certain New York City employers to provide pre-tax commuter benefits to their employees went into effect. Under the law, covered New York City employers must give full-time employees the...more

Extension of ACA Reporting Deadline is Welcome News to Employers

On December 28, 2015, the IRS announced in Notice 2016-4 that the deadlines for complying with the new reporting requirements under the Affordable Care Act (ACA) will be temporarily extended for purposes of 2015 coverage....more

IRS Extends Deadlines for 2015 ACA Reporting

Extension Provides Much-Needed Time to Accurately Complete First Year of Reporting - The IRS has extended the deadlines for information reporting by employers and coverage providers as required under the Affordable Care...more

IRS Extends 2015 Form 1095 Deadlines

Under the Affordable Care Act (ACA), applicable large employers (generally 50 or more full-time employees in previous year) must furnish each individual who was a full-time employee during 2015 with a Form 1095-C,...more

Most New York City Employers Must Offer Commuter Transportation Benefits to Full-Time Employees

New York City’s Mass Transit Benefit Law requires that most New York City employers with at least 20 full-time employees offer such full-time employees the opportunity to use their pre-tax earnings, up to $130 per month, to...more

New Transit Benefit Requirements for D.C. and New York Employers Effective January 1, 2016

Two new laws require employers in Washington, D.C. (D.C.) and New York City (NYC) to offer pre-tax transit benefits, effective on January 1, 2016. Employers with employees in these cities must take action quickly to ensure...more

NYC Employers Must Offer Pre-Tax Transportation Benefits Starting Jan. 1

Effective January 1, 2016, most New York City employers with 20 or more full-time employees will be required by law to offer those employees the opportunity to use pre-tax earnings to purchase qualified transportation fringe...more

ERISA (6th Circuit): So How Many Hours Is Working “Full-time,” Anyway?

What happens when the ERISA long term disability benefit plan does not define “full-time”? The Department of Labor says “full-time” is defined by the employer....more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 19 of 24): Terminations, Changes in Status and...

Last week we examined the reporting challenges associated with employee terminations, changes in status, and breaks in service under the monthly measurement method. As we explained, “[t]he final regulations under Code § 4980H...more

Applicable Large Employers Should Determine Their Full-Time Employees For ACA Purposes And Prepare For Reporting In 2016

By way of reminder, employers who employ at least 50 full-time employees (including full-time equivalents) on average during the calendar year of 2014 will be required to file Internal Revenue Service (IRS) forms 1095-C and...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 18 of 24): Terminations, Changes in Status and...

The final regulations under Code § 4980H establish two—and only two—methods for determining an employee’s status as full-time: the monthly measurement method and the look-back measurement method. Under the former (as the name...more

Gaming the System? ERISA Interference Lawsuit Targets ACA-Driven Reduction of Hours Strategy

In a case believed to be the first of its kind, a recent class action claim has accused an employer of reducing hours of employees to avoid having to provide health coverage as required under the Patient Protection and...more

ACA Automatic Enrollment Mandate Repealed by Bipartisan Budget Act

On Monday, November 2nd, the President signed the Bipartisan Budget Act of 2015 (BBA). Some legislators had hoped that a budget deal would at least include a repeal of the controversial 40% excise tax on high-cost health...more

End of Year Issues Impacting Employer Health Plans

With the end of 2015 fast approaching, employers should be aware of certain issues under the Patient Protection and Affordable Care Act (“ACA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 14 of 24): Coding Form 1095-C, Part II for...

When reporting offers of coverage to full-time employees under the Affordable Care Act’s (ACA) employer shared responsibility rules, much of the detail appears in Part II of IRS Form 1095-C, Lines 14, 15 and 16. For the most...more

Pittsburgh Paid Sick Leave Act Goes Into Effect January 11, 2016

The City of Pittsburgh recently became the second city in Pennsylvania to enact a paid sick leave law, with Mayor William Peduto signing the Paid Sick Days Act into law on August 13, 2015.  While the Act is facing legal...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 13 of 24): Coding Form 1095-C, Part II for...

Compliance with the Affordable Care Act’s (ACA) employer shared responsibility rules requires that applicable large employers identify their full-time employees. A “full-time employee” for this purpose is an employee who...more

Do Seasonal Workers “Count” for Forms 1094-C and 1095-C?

We were asked that recently, proving that there is such a thing as a wrong question. Let’s break it down. The same person may be both a “seasonal worker” and a “seasonal employee,” but those terms are used to discuss separate...more

NYC Affordable Transit Act: Employers Will Be Required to Offer Qualified Transportation Benefits in the New Year

Effective January 1, 2016, most employers with 20 or more full-time employees in New York City must offer those full-time employees the opportunity to use pre-tax earnings to purchase qualified transportation fringe benefits...more

FCC Regulatory Fees Order for FY 2015 Released; September 24 Payment Deadline Set

On September 2, 2015, the FCC released its Assessment and Collection of Regulatory Fees for Fiscal Year 2015 Report and Order (“2015 Regulatory Fees Order”) and set a fee payment deadline of no later than 11:59 PM Eastern...more

Top Ten Healthcare.gov Subsidy Counties in Each SEC State

Why should you care? Subsidy certification of even one applicant claiming to be a full-time employee not offered affordable, qualifying 2015 coverage can cause the IRS to assess a non-deductible tax against the applicant’s...more

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