Renew Early? Pay Later?
While we have not heard it first-hand, we have heard through the grapevine that some insurance carriers are out there offering to their clients the ability to “renew early.” Part of the strategy is, apparently, to delay the application of [...]
Play or Pay: Special Transition Rules For Fiscal Year Plans
Some fiscal year plans may have extra time to comply with the play or pay mandate under either of two special transition rules for fiscal year plans (that is, plans with a plan year other than the calendar year). There [...]
Play or Pay: The Penalties
Effective January 1, 2014, the Affordable Care Act “play or pay” rules become effective for employers subject to the rules. These “play or pay” requirements are also referred to as the employer mandate or the shared responsibility requirements of the [...]
Affordability Calculation Undermines Wellness Programs Beginning in 2015
The Affordable Care Act requires that employers offer affordable health care coverage to full-time employee beginning January 1, 2014 (or pay a penalty). Coverage is affordable if the employee’s contribution toward self-only coverage does not exceed 9.5% of his or [...]
Update: New Hires and Counting Hours for Play or Pay Purposes
Update: The post below has been updated. After discussing this post with an alert reader, we have concluded that the correct reading of the regulations is reflected in Q8-10 below. The good news is: we don’t think there is a hole [...]
The Hole in the Play or Pay Regulations
This post has been updated. Please see the updated version here.
New Hires and Counting Hours for Play or Pay Purposes
This post has been updated. Please see the updated version here.
It’s About Time to Start Counting Up the Hours
Unless you’ve been under a proverbial (or actual) rock for the last several months, you are probably aware that the health reform law has a really big tax that could hit employers for not offering (or not offering good enough) [...]
IRS Talks About Play or Pay (and a Mini-Med Issue to Boot)
In one brief session at the recent TE/GE meetings, we heard from some of the IRS drafters of the PPACA shared responsibility/play or pay regulations under 4980H of the Internal Revenue Code. They provided a few insights on upcoming guidance [...]
The Top 6 Facts You Need to Know About the IRS’s Proposed Play or Pay Regulations
Frequent readers of this blog will recall that the IRS previously issued some initial guidance on the employer “shared responsibility” (aka play or pay) rules under health reform. (A summary of the shared responsibility provisions and the taxes is described [...]



