Guidance on Determining Who is a Full-time Employee & When Health Insurance Must Be Offered

The Treasury and Health and Human Services recently released two new notices concerning the business mandate of the Patient Protection and Affordable Care Act (PPACA).

The first notice, 2012-59, provides information regarding the 90-day waiting period allowed by PPACA.  

The second notice, 2012-58, provides guidance in determining who is considered a full-time employee. This notice is especially important as it provides information regarding the safe harbor method.  The safe harbor method, which would allow an employer to use measurement and stability periods of up to 12 months, would require employers to begin collecting data in 2013 on their employees.  This notice also provides guidance concerning seasonal, short-term assignment and staffing employees.

Both notices have a comment period which ends on September 30, 2012, which means the guidance is subject change.  However, we consider this important information which is why we are sharing the most up to date material on it at this time.

If you have any questions, please feel free to call our office at (781) 407-0300.  Don’t forget to register for one of our year-end tax seminar dates, where the most up to date information on important topics such as the new taxes caused by the PPACA and how to minimize them will be covered.

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