Employer Shared Responsibility Regulations (“Pay or “Play”)

The IRS has issued long awaited regulations proving additional guidance for employers on the employer shared responsibility mandate (“Pay or Play”) of the Affordable Care Act (“ACA” or “Health Care Reform”). By way of background, the Pay or Play mandate requires that large employers, those with more than 50 employees, provide coverage to all full-time employees (those working more than 30 hours per week) and their dependents beginning on the first day of the first plan year after January 1, 2014. Such coverage must also pass certain tests to ensure that such coverage is adequate and affordable in regard to the full-time employee.

Please note that this guidance provides some changes to previous assumptions regarding the Pay or Play Mandate that were widely accepted within the benefits community. It is also important to note that these are proposed regulations that could be subject to further change. Unless, or until, a change is issued, employers may rely on the proposed regulations.

 Pay or Play Regulation Update

Kaiser Health Reform: Helpful flow charts

Penalties for Employers under ACA
Health Coverage under ACA Begininning 2014


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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.