News & Analysis as of

New Employer Rules Soften Start of Healthcare Reform

It is a work in progress. There are so many moving parts to Healthcare Reform that implementing the Affordance Care Act (ACA) requires adjustments as theory meets reality. In July 2013, the deadline for large employers to...more

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

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

Government Agencies Release Additional Guidance on Minimum Essential Coverage, Minimum Value and Summary of Benefits and Coverage

As discussed in our March 20, 2013 Legal Alert – Health Care Reform’s Large Employer Play or Pay Penalties: A Checklist for Employers, large employers will be subject to a penalty tax if they either: (1) fail to offer...more

Benefit Issues in Puerto Rico: Impact of the ACA, ERISA and the PBGC

This article highlights some recent developments that employers with Puerto Rico employee benefits arrangements should consider concerning compliance with U.S. federal laws on health care reform and the Patient Protection and...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

Temporary and Contract Workers: Who Is a “Variable Hour” Employee under the Affordable Care Act?

The Affordable Care Act’s employer shared responsibility rules will require large employers (50 or more full-time and full-time equivalent employees) to make an offer of minimum essential coverage to at least 95% of their...more

The Benefits Game - Playbook for Compliance with the Health Care Reform’s Pay or Play Rules for Employers

The Affordable Care Act’s (ACA’s) employer shared responsibility provisions (commonly called “pay or play”) impact “large” employers and go into effect in 2014. Although effective in 2014, employers must plan NOW. Advance...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

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

Play or Pay and Minimum Essential Coverage: What, When and How (Much)?

Beginning in 2014, the Affordable Care Act’s employer shared responsibility rules, the so called “play or pay” rules, impose penalties on an employer with more than 50 “full-time equivalent” employees (a large employer) if...more

On the Manifold Meanings of "Affordability" According to the Patient Protection and Affordable Care Act

The core policy goals of the Patient Protection and Affordable Care Act (the “Act”)—on which there is near universal consensus—are threefold: expand health care coverage; increase the quality of medical outcomes, and reduce...more

Controlling the “Play or Pay Penalty” under Healthcare Reform

Proposed rules issued under the Affordable Care Act clarify the determination of “large employer” status and the calculation of the penalty for controlled groups of employers. This guidance confirms that the penalty is...more

California Weighs In on Essential Health Benefits for Group Health Plans and Insurers

As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...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

IRS Issues Proposed Regulations on Affordable Care Act's "Play or Pay" Requirements – What Employers Need to Know

Starting in 2014, "large" employers (essentially, those with 50 or more "full-time" employees) must offer minimum health insurance coverage to full-time employees or face hefty penalties. These provisions (a.k.a "shared...more

Health Care Reform – What Employers Should be Thinking About Now

Beginning in 2014, the Affordable Care Act will require employers employing 50 or more full-time equivalent employees to offer full-time employees affordable, minimum essential health coverage. If such health coverage is not...more

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