Nevada Health Link Exchange Summit: What Employers Need to Know About Health

Care Reform Katherine L. Georger

Disclaimer

This is an overview. – There is no substitute for reading the statute, rules and

agency guidance. – Check the rules when it is time to comply (see last slide

for link). – Contact your attorney, accountant, tax and/or financial

planner to address questions about your unique business and circumstances.

Many of the rules are provisional. Additional rules and guidance are issued frequently and current provisional rules and interpretations of the ACA may change.

This does not establish an attorney-client relationship. This does not constitute legal advice.

ACA: Key Provisions

Individual Mandate Expansion of Medicaid Employer Responsibility Provisions

– Penalties—covered employer may face penalties for failure to provide any or inadequate coverage to eligible employees.

– Reporting Requirements—Form W-2s; Exchanges; Affordable Insurance Exchange—creates state-

based, joint federal-state, or federally run exchanges – Essential Health Benefit Benchmark – Small Business Health Option Program (SHOP)

Constitutional Challenge

Individual Mandate – Requires vast majority of Americans to obtain “minimum

essential” health insurance coverage – Penalties—individual fails to comply with individual

mandate, will have to pay “shared responsibility payment” (penalty) payable with the individual’s taxes; Upheld under Congress’s constitutional power to tax

Medicaid Expansion – ACA provided additional Medicaid funds, but required

States to cover all individuals up to 138% FPL or risk losing all Medicaid funding Struck down as unconstitutional use of federal power to attach

penalty of loss of all Medicaid funding for opting out of increase

Unanticipated Consequences for Large Employers? States that decline the Medicaid expansion

component of ACA could expand potential liability of large employers – Exchange-eligible employees are full-time employees

(FTE) with household incomes between 138% and 400% FPL

Medicaid expansion would have covered nearly all persons with household income up to 138% FPL

If states reject expansion, FTE with household income of 100% to 138% FPL eligible for the exchange and eligible to get a subsidy or tax credit

Employer Responsibility Provisions

Employer-Related Issues

– Employer Responsibility Provisions Penalties: large employers’ failure to provide ANY coverage or

INADEQUATE coverage to full-time employees (and their dependents)

Reporting Requirements: large employer must file return certifying it offers full-timers(and their dependents) opportunity to enroll in minimum essential coverage and report number of full-timers.

– Tax Related Issues Form W2s: cost of coverage (250+ employees) Small Business Tax Credits: less than 25 full-timers, avg.

income < $50,000.

– Exchanges Employer Reporting Requirements: Coverage & COBRA

elections

Employer Responsibility Provisions Applicable “large employer” may be subject to an

“assessable payment” (penalty) if: – It fails to offer its “full-time employees” (and their

“dependents”) the opportunity to enroll in a “minimum essential coverage” employer-sponsored plan; OR

– The full-time employee’s contribution for “self-only coverage” exceeds 9.5% of the employee’s “household income;” OR

– The employer-sponsored plan fails to give the full-time employee “minimum value”

Penalty ONLY triggered if a full-time employee applies for and receives a premium subsidy or tax credit*

Employer Responsibility Provisions: Covered Employers Beginning Jan. 1, 2014— “large employers” may

face penalties for not offering health coverage or for failing to offer adequate coverage – Large employers are employers with at least 50 full-time

equivalent employees Hours of part-timers (those working less than 30 hours per

week) are included in calculation of “large employer”; HOWEVER, part-timers are not eligible to receive tax credit

Hours of seasonal workers may count

– Only large employers who have at least one full-time employee (FTE) receiving premium subsidy or tax credit through an exchange and employ at least 30 full-time workers may pay penalty

Potential Employer Penalties: No Coverage Large employer’s failure to provide any coverage

– If covered employer does not offer coverage full-timers and at least one of its full-timers receives a “premium tax credit” or “cost sharing subsidy,” then employer is assessed penalty of $2,000 per full-time employee beyond company’s first 30 full-time employee.

– Assessed on monthly basis – Example: Company A has 100 full-timers but no full-

timers receive credits. Penalty? No—because employer penalty only triggered upon full-time

employee’s receipt of tax credit

Employer Penalties: No Coverage (cont.) Example: Company B has 30 full-timers and 100

part-timers. Penalties? – No—employer is considered “large employer” with 80

full-time equivalent workers; however, penalty is only assessed against number of full-time employees beyond the first 30 full-timers.

Example: Company C has 50 full-timer and one full-timer files for tax credit. Penalties? – Yes, employer will have to pay (50-30)X$2,000=

$40,000 annual assessment.

Potential Employer Penalties: Inadequate Coverage Large employer’s failure to provide “affordable” or

adequate coverage may face penalties if: – Cost of self-only enrollment is more than 9.5% of the

full-timer’s family income OR – Employer’s plan covers less than minimum value or

less than 60% of the health care expenses for a typical population.

Penalty only triggered if full-timer applies for tax credit and obtains coverage on an Exchange. – Employer assessed annual penalty of $3,000 for each

full-timer receiving a tax credit **BUT cannot exceed penalty for offering NO coverage.

Employer Penalties: Inadequate Coverage (cont.) Example: Firm A has 50 full-timers, 10 of which

must pay more than 9.5% of family income and apply for and receive premium credits – Employer will be assessed annual penalty of ($3,000 X

10) = $30,000 Example: firm has 50 full-timers, but coverage is

unaffordable for 20 who receive premium credits. – Employer would be assessed annual penalty of ($3,000

X 20) = $60,000 – HOWEVER, because that penalty exceeds the penalty

of offering no coverage at all, the penalty cannot exceed $2,000 X (50-30) = $40,000

ACA Employer Assessable Payment Flowchart

Employer

50 or more full-time equivalents

(FTEs)

Employer offers

coverage

Tax credit obtained by at least one full-timer because coverage is

“unaffordable” or does not meet “minimum

value

Annual penalty of $3,000 per full-

timer who receives the credit

Tax credit not obtained by any full-

timer

Employee Elects Plan

No employer penalty

Employee rejects Plan

Employee buys own plan

No employer penalty

Employee opts to forgo insurance

and pay individual assessment

No employer penalty

Employer does not offer

coverage

Tax credit obtained by at least one full-timer

Annual penalty of $2,000 X full-

timers (after the first 30*)

Tax credit not obtained by any full-timer

No employer penalty

Less than 50 full-time equivalents

(FTEs) No employer

penalty

Recent Regulatory Guidance

IRS Guidance: Definitions

Employer – Controlled group – Affiliated service group

Employee:“common law” definition – Excludes: leased employee, sole proprietor, partner, 2%

Sub S Shareholder Full-time employee

– 130 hours per calendar month as monthly equivalent Hours of Service

– Paid for work, vacation, holiday, illness, incapacity, layoff, jury duty, military duty or leave of absence

IRS Guidance: Definitions

Large Employer: Means employer employs an average of 50 full-time equivalent employees

Full-time equivalent (FTE): all employees (including part-time, variable, seasonal) who work less than 30 hours per week are included in calculating the employer’s FTEs for a given month

Seasonal Worker Exception: if sum of employer’s full-time employees & FTEs is 50 for 120 days (4 months) or less during the preceding calendar year, not a large employer – The four calendar months and 120 days are not

required to be consecutive

Large Employer

New Businesses: Employers not in existence in preceding calendar year are counted as applicable large employers for current calendar year if they “reasonably expected to employ” an avg of 50+ full-time/FTEs during current year and actually do

Aggregate Rules – All company units (control group & affiliated service groups as defined

under section 414(b), (c), (m) & (o)) count for: Determining large employer status (50 full-time equivalents) and thus,

whether penalties apply Determining 30 first full-time employee reduction in no-coverage

penalty formula (each member gets pro rata share) – Subsidiaries do NOT count for

Determining whether an employer is subject to an assessable payment and amount of that penalty

IRS has said liability is assessed on a individual member basis

Large Employer Determination

Corporation P (no full-timers)

Corporation S (40 full-timers)

Corporation T (60 full-timers)

Which corporations are “large employers”? Which are large employer “members”?

Large Employer Assessment

Corporation A (40 full-timers)

Corporation B (35 full-timers)

•Corp A does not sponsor a plan during 2015 •Corp A receives a “certification” that at least one of its full-timers obtained a premium tax credit for 2015 •How much is Corp A’s assessment? •How much is Corp B’s assessment?

Calculating FTEs

Full-time: At least 30 hours per week or 130 hours per month – Clarifies that ALL periods of paid leave considered

Full-time equivalent: take aggregate hours of service for all non-full-timers (less than 30 hours of service per wk) in given month /120 = FTE month

Calculating hours: – Hourly: ACTUAL hours worked (time cards) – Non-hourly: 3 options; BUT cannot use to understate

Actual Hours Worked Days Worked Equivalency: 8 hours per day Weeks Worked Equivalency: 40 hours per week

Calculating FTEs (cont.)

Foreign Workers: hours worked outside U.S. (outsourced) not calculated for large employer determination

Educators: full-time employees (paid time off) Adjunct faculty, Pilots, Transportation,

Commission: IRS seeking comments – “Reasonable method” to calculate for now – Expect future rules

Dependents

ACA requires large employers to offer “all full-time employees and their dependents”

Dependent: IRS has interpreted to this to mean ONLY an employee’s children who are under 26 years and not spouse or domestic partner – Transitional Relief Safe-harbor: Employer begins to “take steps”

during the 2014 plan year toward offering dependent coverage to full-timers (where it did not formerly offer such coverage), no penalty. ONLY applies for the 2014 plan year.

For purposes of determining “affordability” only need to look at cost of coverage of self-only coverage that cannot exceed 9.5% of wages.

– Dependent coverage and coverage of related individuals is deemed to be affordable based on self-only coverage even if family coverage exceeds 9.5% of the employee’s household income.

– If a related individual (e.g., spouse or dependents) is eligible for minimum essential coverage under the employer-sponsored plan, then they are ineligible for subsidized coverage from a public exchange if the employee premium cost for self-only coverage (not family) does not exceed 9.5% of household income.

Determining Full-Timers

Look-Back Period – Measurement Period

Initial Period—new variable or seasonal hour workers – Optional 3-12 month look back

Standard Period—ongoing workers – Optional 3-12 month lookback

– Administrative Period – Stability Period

Ongoing Employees: standard measurement period (3-12 months), administrative period, stabilization period

Example: Standard-measurement period: Oct. 15, 2013 through Oct. 14, 2014. Administrative period: Oct. 15, 2014 through Dec. 31, 2014. Stabilization period: Jan. 1, 2015-Dec. 31, 2015

Determining Full-Timers

New Employee: any employee who has been employed less than one completed standard measurement period, including new “Break in Service” rules. – Employee may be treated as new employee for purposes of determining

full-time employee status if time of no credited hours of service exceeds 26 weeks.

– Rule of parity: periods with no credited hours of service (of less than 26 weeks) is at least four weeks long and longer than employee’s period of employment immediately preceding that period with no credited hours of service.

New Variable Employees: facts and circumstances of start date, “reasonably likely” to be full-time must be given coverage – Employer cannot take into account the likelihood that it will terminate

employee before the end of the initial measurement period – High turnover position—have to measure because you hired them with

expectation they would be full-time

Short Term & Seasonal Workers

New Short-term Employees: no penalties if employment period less than 3 months

Temp Agencies: Anti-abuse rule – No use of temp agencies to evade penalty provisions.

Seasonal Workers—performs work on a seasonal basis as defined by the Secretary of Labor, including (but not limited to) workers covered by 29 CFR 500.20(s)(1) (agricultural) and retail workers employed exclusively during Holiday seasons. – Employers may apply a “reasonable, good faith

interpretation” of the term “seasonal worker” – Expect future rules & guidance on seasonal workers

Temporary Employees

IRS: will take into account the factual nature of the common law analysis in determining who is the common law employer of the workers providing the services.

IRS: “It is anticipated that many new employees of temporary staffing agencies will be variable hour employees” based on the facts and circumstances – Example: individual hired by temp agency as its “common law

employee” can be expected to be offered more than one or more assignments with different clients each lasting no more than 2-3 months, clients have different requests with respect to hours and gaps between assignments, then employees would be a variable hour employee.

May be instances where employee is full-timer (i.e. technical/professional workers)

IRS has requested further comments

Safe-Harbors

Employer Responsibility Provision Safe-Harbors Large Employer Determination (2014 only)

– Employer look-back to any 6 consecutive month period in 2013 to determine if employed avg. of 50 FTEs

No Coverage – 95% Compliance: large employer deemed compliant if

offers coverage to all but 5% or if greater, 5 full-timers Affordability: Self-Only Coverage

– Form W2: employee’s annual wages (Box 1) – Rate of Pay: hourly rate X 130 hours X 9.5% – Federal Poverty Line: self-only coverage < 9.5% of FPL

Minimum Value – Minimum Value Calculator (HHS rolled out Feb. 2013)

Form W-2 SafeHarbor

Employee A is full-timer of Corp. Z from Jan. 1, 2015 through Dec. 31, 2015. Z offers minimum essential coverage during that period that meets the minimum value requirements.

A’s contribution is $100 per month. A’s Form W-2 wages for 2015 are $24,000 Affordable?

– Yes. Monthly premium ($100) x 12 months to get the employee’s contribution cost ($1,200)

– Next take the employee’s contribution cost and divide by his W-2 annual wage amount ($1,200/$24,000) to get the percentage of the employee contribution (5%)

Form W-2 SafeHarbor

Employee B is full-timer employed by Corp. Y from Jan 1, 2015 through Sept. 30, 2015.

Y offers B and her dependents minimum essential coverage during that period that meets minimum value requirements.

B’s contribution is $100 per month. B’s Form W-2 wages are $18,000 Affordable?

– Yes. $100 X 9 months (# months employed & offered coverage)= $900/$18,000=5% of employee’s wages.

Form W-2 SafeHarbor

Employee C is full-timer employed by Corp. X from May 15, 2015 through Dec. 31, 2015.

X offers C coverage on Aug. 1, 2015 (90 day waiting period).

Employee contribution for self-only coverage is $100 per calendar month.

C’s Form W-2 wages are $15,000 Affordable?

– Yes. Take wages ($15,000) and multiple by 5/8 (the proportionate share of covered months over employed months during the year)= $9,375; multiply that figure by the employee’s contribution cost ($500)=5.33%of wages

Rate of Pay SafeHarbor

Co. employs D full-time from Jan. 1, 2015 through Dec. 31, 2015. Co. offers D and his dependents minimum essential coverage during the period that meets the minimum value requirements.

Employee contribution is $85 per month D is paid a rate of $7.25 per hour for the entire year. Take 130 hours (monthly) service X $7.25= $942.50 Compare $85 figure to assumed income $942.50 Affordable?

– Yes. $85/$942.50=9.01% of employee’s income per month

Rate of Pay SafeHarbor

E employed by V from May 15, 2015 through Dec. 31, 2015.

V offers E coverage from Aug. 1-Dec. 31, 2015 Employee contribution for self-only coverage is

$100 per month. May 15-Oct. 31, 2015, E paid $10 per hour Nov. 1-Dec. 31, 2015, E paid $12 per hour Affordable?

– Yes. V may assume that E earned $1,300 per month (130 hours of service X lowest hourly rate of pay for calendar year); $100/$1,300=7.69% of income per month

FPL SafeHarbor

F is employed by W from Jan. 1, 2015 through Dec. 31, 2015. W offers coverage providing minimum essential coverage during

the period that meets minimum value. W uses a “look-back measurement” method, under which F is

treated as a full-timer the entire year. W is credited with 35 hours per week, but only works 20 hours

in March and 15 hours in August FPL for individual is $11,170. W determines monthly

contribution of 9.5% X $11,170 = $1,061. 15/12=$88.42 monthly contribution

Affordable? – Yes. Because regardless of F’s actual wages for any calendar month

(like March and August when F has lower wages b/c of lower hours of service), coverage is treated as affordable under the FPL Safeharbor

HHS & IRS: Minimum Value

HHS Final Rule: Minimum Value

February 25, 2013: HHS issued final rules on Minimum Value and described several options for determining MV. – Use the Minimum Value Calculator – Safe Harbors developed by HHS or IRS – Non-standard plans: Actuarial certification from a

member of the American Academy of Actuaries – Small group plan: provides bronze level plan.

MV Calculator

Allows employers to determine if their employer sponsored plan covers no less than 60% of total allowed costs

Based on 2009 data where enrollees continuously enrolled for 12 months

Denominator: avg allowed cost of all services for the standard population in the year

Numerator: share of avg allowed cost covered by the plan, using the cost-sharing parameters specified

MV Calculator

Select user inputs for plan parameters – Integrated (applies to both medical & Rx) or Separate

deductible, maximum out-of-pocket, and/or coinsurance spending limits

– Grandfathered Plan Option—user may enter cost-sharing for preventive services (cannot select this option for other plans)

– HSA/HRA Employer Contribution Option – Blended Network/Point of Service (POS) Plan

MV Calculator available at: cciio.cms.gov/resources/files/mv-calculator-final-2-20-2013.xlsm http://cciio.cms.gov/resources/regulations/index.ht

MV: IRS Proposed Regulations

May 3, 2013: IRS Proposed Regulations—purpose to clarify the health benefits considered in determining the “share of benefit costs paid by a plan.” – HSAs: employer contributions for current plan year

considered in determining plan’s share of costs for MV. – HRAs integrated into group health plan: employer’s

current year contributions considered in plan’s share of cost only for cost-sharing

– Wellness programs: reduction in cost-sharing through wellness programs may count toward MV only if every individual satisfies the terms of a non-discriminatory program aimed at tobacco prevention/reduction.

MV Safeharbors

IRS proposed rule has three safe harbors for determining MV – Plan with a $3,500 integrated medical & drug

deductible, 80% cost sharing and $5,000 max out of pocket limit.

– Plan with $4,500 integrated deductible; 70% cost sharing, $6,400 max out of pocket limit, $500 employer contribution to HAS.

– Plan with $3,500, $0 drug deductible, 60% medical cost sharing, $10/$20/$50 copay tiered drug plan and 75% coinsurance for specialty drugs.

– IRS has request suggestions for other common plans that would satisfy MV.

IRS MV Regulations: Other Issues Clarifies that former employees eligible for retiree

coverage are excluded from eligibility for premium tax credits only if they enroll in such coverage

Active employees eligible for COBRA coverage b/c of reduced hours will have eligibility for premium tax credit determined applying the same MV rules that apply to other active employees.

Employer penalty & FLSA violation if: – Employer that fails to offer MV but requires employees

to accept a sub-MV plan (DQ’ing the employee from receiving a premium tax credit b/c he/she is enrolled in employer coverage).

IRS Proposed Regulations: Affordability Affordability: employer HSA contributions &

contributions to HRAs integrated into group health plan (cost-sharing only) can be considered to increase the affordability of employee coverage. – Wellness incentives that reduce premium will NOT be

considered to increase affordability except for premiums charged to tobacco users who complete a non-discriminatory wellness program related to tobacco use.

– 2014: if employee receives premium tax credit because plan unaffordable, employer not subject to employer mandate penalty if: Coverage would have been affordable had employee satisfied

requirements of the non-discriminatory wellness program in effect at the time of the publication of the rule.

HHS Guidance: Exchange Verification & Appeal

Process & Appeals

1. Employee seeks coverage through the Exchange and seeks subsidies for coverage.

2. If not eligible for Medicaid, Exchange will make a determination on eligibility for subsidies based on information provided by employee (employee supposed to provide all relevant information regarding plans available from employer(s))

3. Notice of Eligibility provided to employee and employer

– Small employers may receive these – this does not mean there is liability for penalties.

Process & Appeals

4. If employee denied tax credit/cost sharing subsidy, has 90 days to appeal to the Exchange

30 days to appeal to HHS, judicial review 5. If employee is held eligible for tax credit/cost

sharing subsidy, employer has 90 days from the date of the determination letter to request an appeal to the Exchange

– Appeal can be requested by telephone, mail, in person where available, or by Internet.

– Employee notified of appeal and both opportunity to submit additional information to the Exchange (i.e. Employer may want to show that individual is not an “employee” or that it meets a safeharbor

Process & Appeals

5. Appeal must be of determination that employer – Does not offer coverage; – Offers coverage that is not affordable; or – Offers coverage that does not meet the minimum value

standards Review by one or more impartial officials who have not been directly involved in the employee eligibility determination.

6. Exchange/appeal agency must provide written appeal decision within 90 days of the date the appeal request is received.

– Unlike individual appeal, employer has no right to appeal to HHS in the event Exchange rules unfavorably upon the appeal

Process & Appeals

Employer may contest tax penalties through separate IRS tax appeal procedures.

Unclear how Exchanges, HHS & IRS will coordinate information that arises from these various procedures

HHS currently working on standardized template for employers to use to gather, submit and disseminate information about their coverage options to allow an Exchange to verify whether an employee has access to employer-based insurance coverage and/or the value of that coverage

Employer Checklist

Employer Responsibility Provision Checklist Step 1: Large Employer

– Most will be clear, but for those close to 50 FTEs, need to consider Aggregate Rules & Methods of Calculation

Step 2: Determine full-timers – Look-Back Period (standard measurement period)

Step 3: Determine affordability – W2 Form, Rate of Pay, FPL

Step 4: Determine minimum value – Minimum Value Calculator

Step 5: Certification, Process & Appeal – HHS working on standardized template for employers to

use to gather, submit and disseminate info about plans

Employer Notice Requirements

Employer Reporting Requirements: 2013 January 2013: Beginning with the 2012 taxable

year, employers with 250+ are required to report the value of the employer-sponsored group health plan benefits on employees’ annual Form W-2 – Mandatory reporting for ALL large employers 2015

Employer Reporting Requirements: 2013 March 2013: Employers must provide written

notice to all new hires and current employees of: – Existence of an exchange – Employee’s potential eligibility for tax credit and subsidy – Employee’s potential loss of employer contribution if

employee purchases plan through exchange Small employers should provide notice too DOL has extended Exchange notice deadline to

“late Summer or early Fall 2013”

DOL: Temporary Guidance & Model Notice Applicable employers?

– Section 18B of the FLSA: (1) one or more employees; (2) interstate commerce; (3) generally at least $500,000 in annual volume of business; (4) hospitals, nursing homes, schools

Who gets notice? – All employees regardless of plan enrollment status or

part-time/full-time status Content?

– Must inform employees (1) of the Exchange; (2) eligibility to qualify for tax credit; (3) loss of employer contribution & that all or some of the contribution may be excludable from income for income tax purposes.

DOL: Temporary Guidance & Model Notice Timing?

– New Hires: Must provide notice to new employees at the time of hiring beginning on October 1, 2013; 2014: DOL considers notice timely if provided within 14 days of

employee’s start date

– Current Employees: Must provide notice not later than October 1, 2013;

Manner? – Notice must be automatic and free of charge to

employees & must be provided in writing either: Via first-class mail OR electronically pursuant to 29 CFR

2520.104b-1.

DOL: Model Notices

One model for employers who do not offer health pan

One model for employers who offer a health plan to some or all of its employees

Employers may use, these models or a modified version, provided the notice meets the content requirements.

COBRA Model Notice: revised to make qualified beneficiaries aware of other coverage options available on the Exchange.

http://www.dol.gov/ebsa/healthreform/

Whistleblower Provisions

Whistle blower Provisions

DOL: No employer shall discharge or discriminate against “any employee with respect to his or her compensation, terms, conditions, or other privileges of employment” because employee has “received” credit or subsidy. – Employee’s hours or pay may not be reduced for having

received a subsidy – Leaves open whether courts will view whistleblower

provisions as applicable to the reduction of an employee’s hours so that employee would not have coverage and also not be full-time an ineligible for subsidy (triggering event to employer penalties)

Complainant must show that protected activity was a “contributing factor” leading to the adverse employment action

Whistleblower Provisions

IRS interprets whistleblower provisions to close loophole: – Mandatory enrollment in unaffordable plans will be

viewed the same as not supplying any benefits and the employer will be penalized as though it did not offer any coverage at all (i.e. $2,000 X (# full-timers-30)).

IRS’s interpretation means that employee does not actually need to receive the premium subsidy/credit in order for the ACA whistleblower protection to apply.

Small Business Opportunities

Small Business Health Option Program Small Business Health Option Program: Eligible

employees may receive subsidies for coverage obtained through SHOP exchange (if make between 133%-400% FPL) – April 1, 2013: Obama administration announced delay in

33 federally-run SHOP exchanges Benefit of offering coverage: premiums are tax

deductible for the employer (lose out on tax deduction if stop offering coverage)

Small Business Tax Credits

Small businesses (up to 25 FTEs with average annual salary of less than $50,000) can get up to 50% tax credit for 2014 and 2015 if they purchase coverage from a SHOP

Got Questions?

Want more?

Contact: Katherine L. Georger – klgeorger@hollandhart.com

For more information about health care topics, including the ACA, and for a schedule of our upcoming health law events please visit Holland & Hart’s Health Law Blog – www.hhhealthlawblog.com

Resources

For general ACA information and recent regulations, including the IRS’s Proposed Employer Responsibility Provision rules visit – http://www.cms.gov/cciio/index.html

The Center for Consumer Information & Insurance Oversight – http://www.cms.gov/cciio/resources/regulations-and-

guidance/index.html Dep’t of Labor—Notice Requirements

– http://www.dol.gov/ebsa/healthreform/