The time has come for employers to decide whether to play or pay under the employer shared responsibility mandate in the Patient Protection and Affordable Care Act of 2010 (health care reform). If the answer is to play, employers need to take steps now to comply with the employer shared responsibility requirements and avoid significant penalties that may apply for failure to offer coverage to full-time employees or for offering unaffordable or insufficient coverage to full- time employees.
Recently issued proposed regulations expand upon and clarify prior guidance issued in the form of Notices and provide some transitional relief. Employers may rely on the proposed regulations pending issuance of final regulations or other guidance and will be provided sufficient time to comply with any future guidance that is more restrictive. Set forth below are some of the significant items in the new guidance. And following that is an update of the summary of the employer shared responsibility rules we provided in our November "Health Care Reform Update," which now incorporates the guidance in the proposed regulations.
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