Alert / Employee Benefits
Part II: IRS Proposed Regs on “Play or Pay,” Determining FT Employees

On the last business day of 2012, the IRS issued 144 pages of proposed regulations addressing the employer "play or pay" mandate under 2010's federal health reform law, the Patient Protection and Affordable Care Act (PPACA).

We dealt with half of the regulatory package in Part I of our two-part Alert package on the proposed regulations. In this Part II we address: how the IRS proposes larger employers count hours of service, for determining "full-time employees" under the play or pay mandate; how hours for some employees may be averaged over extended periods; and other related matters.

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