News & Analysis as of

Full-Time Employees Look-Back Measurement Period

Seyfarth Shaw LLP

Different Strokes for Different Folks: The Feasibility of Implementing Different Benefits Plans for Different Categories of...

Seyfarth Shaw LLP on

In the growth of the gig economy, many employers are increasing the number of categories of their employees and associates. One challenge of the gig economy is determining when a worker qualifies as a full-time employee for...more

Mintz - Employment, Labor & Benefits...

Staffing Firms, Educational Organizations, and Breaks-in-Service under the Affordable Care Act Employer Shared Responsibility...

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

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 19 of 24): Terminations, Changes in Status and...

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

Winstead PC

Finding Liberation in the Big Picture of the Employer Shared Responsibility Tax

Winstead PC on

Introduction - 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’’) say, that some of the most significant...more

Littler

ACA Outlook: What Will 2015 Hold for the Affordable Care Act and Employers?

Littler on

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

Mintz - Employment, Labor & Benefits...

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

King & Spalding

Determining Full-Time Employee Status for ACA: IRS Issues Guidance for Changes in Measurement or Methods

King & Spalding on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

‘Tis the (Retail) Season, Part IV: Are Seasonal Workers Entitled to Health Care Coverage? A 2014 Update

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

New ACA Guidance Permits Employer-Initiated Measurement Period Changes

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

Eversheds Sutherland (US) LLP

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

Franczek P.C.

Monthly Benefits Update - September 2014

Franczek P.C. on

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

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in...

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

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 23: The Impact of Employment Contract Terms on Variable Hour...

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

Dickinson Wright

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

Dickinson Wright on

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

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