As 2014 rapidly approaches, employers of all sizes and all industries are working hard to avoid the Affordable Care Act’s (the “Act”) Employer Mandate, now appearing in the Internal Revenue Code, Section 4980H. For employers who employ a stable, salaried workforce, and who already sponsor a robust health plan for that workforce, the transition to 2014 will be largely seamless. But step away from that model and the terrain begins to get rocky. The Act’s rules are less easy to apply for employers with large cohorts of variable hour employees (such as those in the staffing and restaurant industries); those with untraditional ways of counting service (such as educational institutions) and — the subject of this advisory — employers subject to collective bargaining agreements who provide medical benefits through Multiemployer Plans.

A Very Brief & Over-Simplified Overview of the Employer Mandate -

Our client alert issued January 16, 2013 discusses the Act’s Employer Mandate at length. Here are the highlights of the Employer Mandate...