The Patient Protection and Affordable Care Act ("ACA") contains complex rules regarding employer shared responsibility, often called the “pay or play” requirement. These rules require employers to offer minimum essential health coverage to full-time employees, or pay a penalty if even one employee receives a subsidy in the public insurance exchange. There has been some guidance from the Internal Revenue Service (IRS) and Department of Labor (DOL) on these rules, but very little of it specifically addresses issues affecting multiemployer health and welfare plans.
Proposed regulations issued by the IRS on December 27, 2012 contained a transition rule that provided limited relief through 2014 for employers who contribute to multiemployer health and welfare plans. The IRS requested comments on its proposed regulations by March 18, 2013, with a public hearing scheduled for April 23, 2013.
In response to the IRS’s request for comments, Horizon Actuarial Services, LLC and the Mechanical Contractors Association of America (MCAA) prepared a joint letter asking that there be a general exemption for collectively-bargained employees who are covered under multiemployer health and welfare plans. The letter noted that multiemployer plans have unique characteristics, and they play a very important role in providing comprehensive health coverage to thousands of workers and their families. The letter also commented on issues regarding the transition rule through 2014 and additional issues that will arise in 2015 and beyond, after the transition rule expires.
A copy of the letter can be found below.
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MCAA/Horizon Comments to IRS on ACA
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Proposed regulations issued by the IRS on December 27, 2012 contained a transition rule that provided limited relief through 2014 for employers who contribute to multiemployer health and welfare plans. The IRS requested comments on its proposed regulations by March 18, 2013, with a public hearing scheduled for April 23, 2013.
In response to the IRS’s request for comments, Horizon Actuarial Services, LLC and the Mechanical Contractors Association of America (MCAA) prepared a joint letter asking that there be a general exemption for collectively-bargained employees who are covered under multiemployer health and welfare plans. The letter noted that multiemployer plans have unique characteristics, and they play a very important role in providing comprehensive health coverage to thousands of workers and their families. The letter also commented on issues regarding the transition rule through 2014 and additional issues that will arise in 2015 and beyond, after the transition rule expires.
A copy of the letter can be found below.
- – – – – – – – – – – – – – – – – – – – – – – – – – – – -
MCAA/Horizon Comments to IRS on ACA
- – – – – – – – – – – – – – – – – – – – – – – – – – – – -
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