News & Analysis as of

The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for...

The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...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

Are You Too Cozy With Your Independent Contractors?

January 1, 2015 is fast approaching, and with it, the first year the employer mandate applies to employers with 100 or more full-time employees (50 in 2016) – the “Play or Pay” rules. In preparation for this new law,...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

ACA Pay Or Play: Is Your Dependent Coverage Compliant?

Now that the IRS has issued final regulations under Section 4980H, the so-called “pay or play” provision of the Affordable Care Act, employers are deciding how to determine whether employees are full-time (30 hours or more a...more

Final Employer "Play or Pay" Mandate Guidance: Employer Action Needed

The federal health care reform law enacted in 2010, known as the Affordable Care Act, added a provision to the Internal Revenue Code (“Code”) (Code Section 4980H) that, beginning on January 1, 2015, may subject employers to...more

Final ACA Shared Responsibility Regulations Released

Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more

IRS Final Rule Partially Delays ACA Employer Shared Responsibility Requirement

On January 10, 2014, the Internal Revenue Service (IRS) released final regulations governing the employer shared responsibility provisions of the Affordable Care Act (ACA). The final rule addresses application of the...more

Preparing for the Affordable Care Act - A Brief Guide for the Small Business

The steps a small business should take to prepare for the Patient Protection and Affordable Care Act (“ACA”) vary greatly depending on the size of the business and how many employees it has. Small businesses with fewer than...more

A Vignette of Lingering Affordable Care Act Considerations

Despite the highly publicized announcement that enforcement of the “Pay-or-Play” mandate (which requires businesses to provide health insurance to all full-time employees or face yearly penalties of up to $3,000 per employee)...more

Obama Administration Delays Enforcement of the ACA Employer Shared Responsibility Rule to 2015

In a move that took many by surprise, the Obama Administration on July 3 announced a one-year delay (to January 1, 2015 from January 1, 2014) in the enforcement of the employer mandate under the Patient Protection and...more

Update: Employer Responsibilities Under The Affordable Care Act

ON JULY 2 THE OBAMA ADMINISTRATION ANNOUNCED A ONE YEAR DELAY OF REQUIREMENTS FOR LARGE EMPLOYERS (50 OR MORE FULL-TIME EMPLOYEES) TO REPORT THE HEALTH CARE COVERAGE THEY OFFER THEIR EMPLOYEES, AS WELL AS PENALTIES FOR...more

The Employer’s Playbook for ACA Compliance: Ten Practical Strategies for 2014

The Affordable Care Act (a/k/a Health Care Reform, or the ACA) is complicated. While there is nothing in the ACA that requires any employer to provide group health care coverage to its employees, the failure to do so can come...more

Employers Must Comply With New DOL Notice Requirement Regarding Health Care Exchanges Under Affordable Care Act

On May 8, 2013, the Department of Labor (DOL) released new guidance imposing notice requirements on employers regarding the health care exchanges that are a key element of the Affordable Care Act. ...more

Strategic Implementation of Employer Shared Responsibility Rules & 2014 Planning Considerations

In This Presentation: •Welcome •Overview of the Employer Shared Responsibility Rules - Impact on Corporate Structure - Time Line Examples to Demonstrate Application of Measurement, Administrative & Stability...more

Who is a Large Employer Under Obamacare?

Among other things, the Patient Protection and Affordable Care Act (the “Act”), commonly referred to as Obamacare, requires “large employers” to provide qualified health coverage for all of their full-time employees, or pay...more

The Obamacare “Play or Pay” Rules: A Practical Approach

The IRS recently released new proposed regulations to implement the Shared Responsibility or “Play or Pay” provisions of Health Care Reform. The proposed regulations provide a wealth of detail on key issues required to...more

Employer Responsibility – Will You Pay or Play?

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

Staffing Industry Compliance with the Employer Shared Responsibility (aka “Pay-or-Play”) Provisions of the Affordable Care Act:...

Under the Patient Protection and Affordable Care Act (the “Act”), the federal government, state governments, insurers, employers, and individuals all share responsibility to make affordable health insurance coverage widely...more

Benefits Update, No. 2, May 2013: Healthcare Reform: To Play Or Pay – That Is The Question

Probably the most important mandate for employers is the “play or pay” mandate, also known as the employer-shared responsibility, which will require large employers (those with the equivalent of 50 or more full-time...more

The Affordable Care Act’s “Play-Or-Pay” Mandate: Who Is A Full-Time Employee For Purposes Of The Employer Shared Responsibility...

Recently, we published a Client Update explaining how the Play-or-Pay mandate, or Employer Shared Responsibility provision, under the Affordable Care Act (ACA) generally works. To summarize, we described how an employer...more

Affordable Care Act: Preparing for 2014

President Obama’s re-election confirmed that the Affordable Care Act will continue to be rolled out, and that its “pay-or-play” rules will become effective on January 1, 2014. These provisions require public and private...more

Employers Subject To The Play Or Pay Penalties Under Health Care Reform

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

The Affordable Care Act’s “Play Or Pay” Mandate: How It Works

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 2014, certain employers may be subject to a penalty tax,...more

Benefits and Compensation Alert - January 2013: IRS Issues Proposed Regulations On The “Employer Shared Responsibility” Penalties...

To make certain that 2013 will be as exciting as 2012, on January 2 the US Treasury issued proposed regulations under section 4980H of the Internal Revenue Code (“Code”), which was added to the Code by the Patient Protection...more

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