Shared Responsibility Rule Full-Time Employees

News & Analysis as of

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

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

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

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

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

Health Care Reform 2015 – An Update

2015 is a significant year for health care reform because the large employer shared responsibility penalties under Internal Revenue Code Section 4980H take effect for most large employers. ...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 2: Explaining the Look-Back Measurement Method to Employees

Many applicable large employers—i.e., employers that are subject to the Affordable Care Act’s (ACA) employer shared responsibility rules—have a pretty good sense of what these rules are, how they work, and what they plan to...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 9: Misunderstanding “Offer[s] of Coverage on Behalf of Another...

Applicable large employers faced with the prospect of complying with the Affordable Care Act’s employer shared responsibility rules must grapple with and understand what is means to make an offer of minimum essential coverage...more

Proposed Approach for Applying the “Look-Back” Method When the Section 4980H Measurement Period Changes

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

The Affordable Care Act—Countdown to Compliance for Employers, Week 11: Rethinking ACA Compliance Strategies Involving Reference...

Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more

What Employer Shared Responsibility Does Not Say

So much energy has been spent on what the final regulations on the employer shared responsibility tax and the related final reporting regulations (the “ESRR”), that some of the most significant considerations have been missed...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

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

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

Affordable Care Act: Shared Responsibility for Applicable Large Employers

An employer who employed an average of 50 or more full-time employees during the previous calendar year is an “Applicable Large Employer” under the Shared Responsibility provisions of the Affordable Care Act (ACA). The Shared...more

Who is an employee and who is an independent contractor under the employer mandate provisions of the Affordable Care Act...

As we have written in this space in the past, whether a worker is an employee or an independent contractor can have many consequences. The classification can determine whether the principal is liable for the negligent acts...more

Employers Need To Evaluate Coverage Under The Affordable Care Act Now

Beginning in 2014, "large employers" may be assessed a penalty for not providing required coverage under the employer shared responsibility mandate of the Affordable Care Act. This does not mean that employers need not worry...more

Penalties and Measuring Periods for Large Employers - How to Assess Potential Liability under the Affordable Care Act

Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more

IRS Issues Proposed Regulations for Employer-Shared Responsibility under ACA

On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...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

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