Starting in 2014, the “pay-or-play” rules under Internal Revenue Code section 4980H will apply to large employers who employ an average of 50 full-time or full-time equivalent employees. Proposed regulations released earlier this year provide important details regarding how the 4980H rules apply to …
New Guidance on Measuring Full-Time Employee Status
September 4, 2012 Leave a Comment
Newly released IRS Notice 2012-58 describes the voluntary safe harbors that employers may use to identify full-time employees for purposes of the employer mandate. Employers who employ 50 full-time and full-time equivalent employees are subject to the mandate, and the number of full-time employees determines the …
Functions of the Health Care Exchanges for 2014
February 14, 2012 Leave a Comment
For employers to understand the big picture, our earlier posts described the government subsidies, individual mandates and employer mandates. Today, we discuss the role of the new exchanges, beginning in 2014, for employees who don’t have employer-sponsored coverage or unaffordable employer-sponsored coverage. …
IRS Requests Input on Full-time Employee Definition
May 16, 2011 Leave a Comment
On May 3, the IRS issued a request for comments on the employer mandate (or “pay or play”) and the 90-day waiting period provisions of the health care reform law. These provisions are effective in 2014, and before issuing guidance on these topics, the agencies are asking for comments. A key definition for …
Health Care Reform: Looking Ahead to 2014—An Illustration
March 21, 2011 Leave a Comment
Over the course of several blog posts, we’ve looked ahead to 2014 to consider how individual mandates, government subsidies and employer mandates and penalties will interact. Our earlier blog posts, which are linked below, have the details of these provisions, but today we want to apply the details of those …
Health Care Reform Looking Ahead to 2014: Interaction Between Government Subsidies and Mandates—A Comparative Table
March 17, 2011 Leave a Comment
The chart below summarizes the interaction of the various elements of health care reform cost allocation among individuals, employers and the government. Assumptions: $30,000 annual household income ($2,500 per month), qualifies as less than 400% of federal poverty level; Employee portion of least expensive, …