How to Determine Full-Time Employment Status of Employees for the ACA Employer Shared Responsibility Mandate

By on January 5, 2016

As part of the insurance market reforms enacted under the ACA, large employers are required to maintain a certain level of health insurance for their common law employees (and only their common law employees) or pay a penalty — the so-called pay or play or employer shared responsibility rules.  The rules for determining which workers should, or even can, be offered coverage are quite daunting.  This article provides a road map for determining which workers must have an offer of health insurance coverage from the employer to avoid triggering penalties under the employer shared responsibility requirements.

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