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CBIZ M.T. Donahoe & Associates, LLC

ACA Important Update

Play or Pay: In-Depth Information on Final Regulations


Please see our most recent CBIZ Health Reform Bulletin: Exploring Shared Responsibility Rules (HRB91) for vetted in-depth information regarding the final regulations (issued February 12, 2014) surrounding the Employer Shared Responsibility Provision (Play or Pay).


Due to the length of the document, we have included a table of contents below.  Here is what you can expect to find in HRB 91:


·         Employers Subject to the ACA’s Shared Responsibility Requirement-Page 1 

·         Employer Defined

·         Applicability of Control Group Rules

·         Determining Applicable Status

·         Transition Relief Rules

·         Next Steps

·         Who is an Employee and How is an Employee classified for ACA’s Employer Shared Responsibility Requirement?-Page 3

·         Employee Defined

·         Calculating Hours of Service

·         Determining Full-time Employee Status

·         Transition Relief

·         Next Steps

·         What is an “Offer of Coverage” for ACA Shared Responsibility Purposes?-Page 8

·         Affordability Standard

·         Minimum Value Standard

·         Who Must be Offered Health Coverage?

·         Employees of a Controlled Group

·         Next Steps

·         ACA’s Employer Shared Responsibility Provisions Unique to Educational Organizations-Page 9

·         Periodic Breaks during Academic Year

·         Calculating Hours of Service

·         Break in Service Rules

·         Next Steps

·         Illustrative Examples-Page 11


As the ACA and its regulations continue to evolve, we will continue to monitor, evaluate and interpret the changes as they become available. 


Contact us with questions.