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 …
Guidance on 90-day Waiting Periods for Group Health Plans
September 10, 2012 Leave a Comment
For plan years beginning after December 31, 2013, PPACA generally prohibits both grandfathered and non-grandfathered group health plans from imposing waiting periods greater than 90 days. The IRS[1] recently released Notice 2012-59 (the “Notice”), which provides guidance about new limitations on the maximum …
New Guidance on Measuring Full-Time Employee Status
September 4, 2012 1 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 …
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 …