The Massachusetts Department of Unemployment Assistance (DUA) has begun assessing Employer Medical Assistance Contribution (EMAC) supplemental payments for the first quarter. This post proposes a grounds for appealing DUA...more
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
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
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
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
10/29/2015
/ Affordable Care Act ,
American Bar Association (ABA) ,
COBRA ,
Employer Group Health Plans ,
Employer Liability Issues ,
Final Rules ,
Form 1094 ,
Form 1095 ,
Full-Time Employees ,
Health Insurance ,
IRS ,
Part-Time Employees ,
Reporting Requirements ,
Safe Harbors ,
Self-Funded Health Plans ,
Shared Responsibility Rule ,
Termination ,
U.S. Treasury
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
10/23/2015
/ Affordable Care Act ,
Employer Mandates ,
Full-Time Employees ,
Health Insurance ,
Hiring & Firing ,
IRS ,
Minimum Value Plans ,
New Hires ,
Part-Time Employees ,
Penalties ,
Reporting Requirements ,
Shared Responsibility Rule
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
10/14/2015
/ Affordable Care Act ,
Disability Leave ,
Employer Mandates ,
Excise Tax ,
Full-Time Employees ,
Health Insurance ,
IRS ,
Large Employer ,
Penalties ,
Reporting Requirements ,
Safe Harbors ,
U.S. Treasury
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
2/25/2015
/ Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Cafeteria Plans ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Mandates ,
Equal Employment Opportunity Commission (EEOC) ,
Full-Time Employees ,
Health Insurance ,
Honeywell International ,
HSA ,
Minimum Value Plans ,
Pay or Play ,
Self-Insured Health Plans ,
Shared Responsibility Rule ,
Wellness Programs
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
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
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
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
Whether an employer makes the requisite offer of group health plan coverage is critical to the application of the Affordable Care Act’s employer shared responsibility rules as reflected in final implementing regulations...more
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
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
7/21/2014
/ Affordable Care Act ,
Employer Group Health Plans ,
Employer Liability Issues ,
Employer Mandates ,
Final Rules ,
Full-Time Employees ,
Health Insurance ,
Look-Back Measurement Period ,
Part-Time Employees ,
Seasonal Employment ,
Variable Hour Employees
For “applicable large employers” (i.e., generally, those employers who employed an average of at least 50 full-time employees on business days during the preceding calendar year), determining which employees are “full-time”...more
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
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
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