The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more
For many employers, the effective date of the Affordable Care Act's "play-or-pay" mandate is only weeks away. The impending deadline comes amid questions about the future—and perhaps viability—of the law itself. Entering...more
The employer shared responsibility provisions (commonly referred to as the "pay-or-play" mandate) of the Affordable Care Act ("ACA") impose penalties on applicable large employers that fail to offer qualifying health coverage...more
As the holiday shopping season approaches, we are considering a number of issues that employers of seasonal workers might be facing. Primary among these is whether employers are required to provide health care coverage to...more
The Internal Revenue Service (IRS) recently released Affordable Care Act (ACA) guidance addressing how to determine full-time status when an employee’s measurement period changes. The guidance, IRS Notice 2014-49, introduces...more
The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more
Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging...more
IRS Issues Guidance on How to Deal With a Change to an Employee’s Measurement Period Under ACA Employer Mandate - The Internal Revenue Service (IRS) issued Notice 2014-49, which proposes an approach for dealing with...more
Final regulations implementing the Affordable Care Act’s employer shared responsibility rules furnish employers with two alternative methods—the monthly measurement method and the look-back measurement method—for identifying...more
For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more
The Health Care Reform Act made many changes to health plans, but one thing it did not do was expressly eliminate or change the COBRA rules. Although health care reform does not expressly change COBRA, it does, in many ways,...more
For applicable large employers (i.e., employers who employed at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year) endeavoring to comply with the Affordable Care Act’s...more