Reform Update: Employer Shared Responsibility

Starting in 2015 (due to transition relief announced in IRS Notice 2013-45), employers of at least 50 full-time employees (including multiple part-time employees equivalent to full-time employees) will be subject to the Employer Shared Responsibility provisions under section 4980H of the Internal Revenue Code (added to the Code by the Affordable Care Act). If such employers fail to sufficiently offer affordable coverage meeting minimum value, they will be at risk for owing shared responsibility payment.


When do the Employer Shared Responsibility provisions go into effect?

The Employer Shared Responsibility provisions generally are not effective until Jan. 1, 2015, meaning that no Employer Shared Responsibility payments will be assessed for 2014. See Notice 2013 45. Employers will use information about the number of employees they employ and their hours of service during 2014 to determine whether they employ enough employees to be an applicable large employer for 2015.

You may be asked about details around the Employer Shared Responsibility and how it will impact your clients. The IRS has posted a very helpful Questions and Answers page on its website, which you may share with your customers.  Click here to view.

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Stacy Madden