Health Care Reform and How Your Decision Will Affect Your ... · Health Care Reform and How Your...
Transcript of Health Care Reform and How Your Decision Will Affect Your ... · Health Care Reform and How Your...
Health Care Reform and How
Your Decision Will Affect Your
Company
brought to you by Fringe Benefit Group® © 2014
2 2www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
The Contractors Plan
& Fringe Benefit Group
• National TPA administering full benefits array: major medical, limited medical, dental,
vision, life, disability, HRA, retirement, etc.
• Originated the offering of bona fide benefit plans to prevailing wage contractors,
serving thousands of construction contractors over the last 30+ years
• In-house compliance and prevailing wage consulting
• Key Association Relationships: ABC, ADA, PDCA, CICPAC, IWCP, AGC, etc.
3 3www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
• FULL SERVICE INSURANCE BROKERAGE FIRM
• PART OF MARSH & MCLENNAN AGENCY
• SERVE START-UPS TO GLOBAL
ORGANIZATIONS
• CONSTRUCTION / CONTRACTOR PRACTICE
GROUP
• AWARD WINNING ORGANIZATION
Barney & Barney
4 4www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Topics Covered
• Davis Bacon Act & State Prevailing Wage
• Health Care Reform1 and its Impact
• Who is subject to the healthcare mandate?
• Impact of providing / not providing coverage
• Why building a long term benefits strategy is critical
• Business continuity and growth considerations
• Contractor Tools & Resources
1 Patient Protection & Affordable Care Act (PPACA) or Affordable Care Act (ACA)
5 5www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Sample Wage Determination
BASE
WAGE
$30
FRINGE
BENEFIT
$10+
TOTAL HOURLY WAGE
$40
6 6www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Two Strategies for Paying Fringes:
Pay Fringe in Paycheck
Base Wage $30.00
Fringe $10.00
Total Wage $40.00
Payroll Burden(25%) $10.00
Labor Per Hour Cost: $50.00
$2.50/hr. savings per
person before ACA
Tax Penalty
Pay Fringe to “Bona Fide” Plan
Base Wage $30.00
Total Wage $30.00
Payroll Burden(25%) $ 7.50
“Bona Fide” Plan $10.00
Labor Per Hour Cost: $47.50
7 7www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Plumbing Contractor
• About 75% of this contractor’s work is government
– 2080 annual hours x 75% = 1560 hours
• There are 75 hourly employees
• The hourly savings by removing the fringe from payroll is
$2.50
• The annual savings is significant:
– 1560 hours x 75 EEs x $2.50 hour = $292,500
– Nondeductible ACA penalty for 75* employees = $90,000
– Net total annual savings = $382,500
In addition, many contractors unknowingly pay for health premium and / or retirement
contributions “on top” of paying the fringe as wages!
* For 2016, total number of EEs minus first 30 x penalty
8 8www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Apprentice Rates
• Apprentice rates are a percentage of the base wage.
• Apprentice fringes remain the same as the job class*
– Base $30.00 Fringe $15.00
• 60% apprentice Base $18.00 Fringe $15.00
• 75% apprentice Base $22.50 Fringe $15.00
• Number of apprentices allowed is an acceptable ratio to
journeymen.
* Can vary by state and / or apprenticeship program.
9 9www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Total Financial Impact – Add It All Up!
• Payroll burden savings
• Tax penalties for not providing coverage
• Retirement plan profit sharing contribution offset and / or
increased deferrals for HCE’s
• Effective use of apprentices
• Tax deduction for health plan contributions (on private work)
• For small businesses, potential for tax credits
• Grant money for wellness programs
• Some contractors pay fringe as wages and offer health
coverage
• Single source: product, administration & compliance support
10 10www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
The Patient Protection & Affordable Care Act
• Health Care Reform is the “new normal”
• Some elements are still awaiting final guidance
• Impacts all employers and individuals
• Creates additional and complex compliance requirements with
potentially higher costs
• Employers need to build a benefits strategy that considers the long
range impact on their businesses
11 11www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
ACA Regulation/ActionCheck out link below to PPACA implementation timeline:
http://healthreform.kff.org/timeline.aspx?source=QL
12 12www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Who is Subject to the Mandate?
13 13www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Control Group Breakdown
Corporation A• Corporation A owns 100%
of Corporation B
• Employs 40 full-time employees in each calendar month of 2015
Conclusion:
Corporation A and corporation B are members of a controlled group that employs 50 or more full-
time employees and, therefore, are large employers subject to the employer mandate in 2016
Corporation B• Employs 35 full-time
employees in each calendar month of 2015
14 14www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Large Employer Exceptions
• Seasonal Employees – If the company’s employment exceeds
50 full-time equivalents for 120 days or fewer (or 4 months) in
calendar year solely as a result of seasonal employees, not
considered a large employer. (100 for 2015 determination)
• 2014/15 Transition Rule – May use 6 consecutive months in
2014 for 2015 Large Employer status. (Rather than average
all 12 months.) This may apply in future years.
• New businesses must predict whether they will average at
least 50 full-time employees during the year. (100 for 2015
determination)
15 15www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
What is the Employer Mandate?
• Large employers (those who average 50 or more full-time
employees in the prior calendar year) must offer medical
coverage to full-time employees beginning in 2016. (100 for
2015)
• If employer does not offer medical coverage to full-time
employees, is subject to annual $2,000 fee/tax per all full-time
employees (1/12th for each month without coverage) if any one
employee receives government premium tax credit.
• If employer offers coverage, but it is unaffordable or doesn’t
meet minimum value rules, subject to annual $3,000 fee/tax
(1/12th/month) per employee that receives government
premium tax credit.
16 16www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Who Requires Coverage?
• Full-time employees of Large Employers must be eligible for
coverage. Part-time employees do not require coverage. Small
employers are not required to provide coverage.
• Evaluated on a month by month basis. May use the Monthly
Measurement Method or a Look-back Measurement Method
approach to determine who is full-time based on historical
hours employed.
• New employees are treated differently than ongoing
employees under the look-back method.
17 17www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Monthly Measurement Method
• New full-time employees must be covered the day after the
first three full calendar months they are full time employees,
beginning with the first full calendar month the employee
would otherwise be eligible under the terms of the plan.
• The same rule applies to all other new employees. For
example, if an employee worked part-time (averaged less than
30 hours per week) for 6 months, but then began working full-
time the first day of the 7th month, the employee would need to
be covered the first day of the 10th month.
• After this point, employees would continue coverage, but
would NOT need to be covered in months that they do not
work 30 hours per week on average during a month.
18 18www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Look-Back Method to Determine Full-Time
• May use historical hours of service to determine full-time
status of an ongoing employee during the “standard
measurement period”.
• If an employee averaged 30 hours per week (or 130 hours per
month) during the measurement period they are considered
full-time during the following “stability period”.
• If an employee did not average 30 hours per week, they are
not considered full-time (and not subject to coverage) during
the following stability period (subject to time limits).
19 19www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Full-Time Status for New Employees(Look-Back Method)
• New employees that are “reasonably” expected to have at
least 30 hours of service per week (and are not seasonal
employees) are treated as full-time employees subject to
coverage in 90 days to avoid tax.
• All other new employees may utilize a measurement and
stability period to determine whether they will be treated as
full-time employees subject to coverage. Referred to as “New
Variable Hour, Seasonal and Part-Time Employees.”
20 20www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Look-Back Measurement Method –
Ongoing EEsStandard Measurement
Period (SMP)
• Determine which
employees paid for 30
hours/week or 130
hours/month
• 3-12 consecutive calendar
months chosen by the
employer for employees in
the same category
• Categories include unions,
salary/hourly, different
states or employers in
controlled group
Administrative Period
(AP)
• To finalize calculations of
SMP and enroll
employees
• Up to 90 days as chosen
by the employer
• Falls between the
Standard Measurement
Period and the related
Stability Period
• Overlaps with prior
Stability Periods
Stability Period (SP)
• Must be at least six
consecutive calendar
months up to 12
consecutive months
• Must be at least as long
as the SMP
• If considered Full-Time in
the SMP, then
considered FT in SP
• If not FT in SMP, then
not treated as FT in
stability period (SP for
these employees may
not exceed SMP)
21 21www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Look-Back Measurement Method – New EEsOnly applies to variable hour, seasonal and part-time employees (those not reasonably
expected to work more than 30 hours per week).
Initial Measurement
Period (IMP)
• Determine which new
variable hour, seasonal
or part-time employees
paid for 30 hours/week
or 130 hours/month
• 3-12 consecutive
calendar months, as
chosen by the employer,
for all employees in the
same category (see
Ongoing EE rule for
categories)
Administrative Period
(AP)
• Up to 90 days as chosen
by the employer
• However, IMP and the
AP combined cannot
extend beyond the last
day of the first calendar
month beginning on or
after the employee’s 1
year anniversary date
• Falls between the IMP
and the SP
Stability Period (SP)
• 6-12 consecutive months
and no shorter than IMP
• Must be same length as
the stability period for
ongoing employees
• But EEs with less than
30 hours/week in IMP,
SP may not be more
than one month longer
than the IMP, or past the
remainder of SMP (and
AP)
22 22www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Look-Back Method – New Variable Hour EE
• Once a new variable hour, seasonal, or part-time employee is
employed for a full SMP, they are tested the same as any
other “ongoing” employee
• If determined to be full-time during IMP, but not during the
overlapping SMP, must continue full-time status at least
through the end of the initial stability period
• If determined to not be full-time during IMP, but is during the
overlapping SMP, treated as full-time as soon as the standard
stability period begins (even if ISP is longer)
23 23www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Look-Back Method – Change Employment
• If a new variable hour, seasonal, or part-time employee duties
materially change (if were a new employee would be expected
to work 30/hours per week) they become eligible for coverage
no later than the 1st day of the 4th month after the change (or if
earlier, the beginning of the ISP, if averaged 30/week during
IMP)
• If an ongoing employee changes actual employment duties to
or from full-time status during a standard stability period, they
remain the original status for coverage until the end of the
stability period, regardless of the change
24 24www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Rehired Employees
• Employees that terminate employment for at least 13 weeks
and are rehired may be treated as a new employee under the
ACA rules, rather than a continuing employee.
• Employers may elect to use a period of as low as 4 weeks
terminated (rather than 13) to treat an employee as a new hire,
if the period of time the employee worked prior to the
termination was less than the time they were gone. This is
called the rule of parity in the regulations.
25 25www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Measurement Period Example
New Part Time
EE
Ongoing
Employee
2014 2015 2016
Initial Measurement Period
May 10, 2014 – May 9, 2015
Administrative Period
May 10, 2015 – June 30, 2015
Stability Period
July 1, 2015 – June 30, 2016
Standard Measurement Period
Oct 15, 2014 – Oct 14, 2015
Administrative Period
Oct 15, 2015 – Dec 31, 2015
Stability Period
Jan 1, 2016 – Dec 31, 2016
26 26www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
What if you don’t cover 100% of full-time
• Generally, 5% of full-time employees (or 5 employees if
greater) could be excluded from the plan but still avoid the
$2,000 annual tax penalty per full-time employee not covered.
• During 2015, the IRS has changed this rule allowing up to
30% of full-time employees to be excluded from an offer of
coverage yet still avoid the $2,000 annual tax penalty.
• Regardless, the employer will still be liable for the $3,000
annual tax penalty for those full-time employees who were not
covered, and who received a premium tax credit from the
government for the year.
27 27www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
What is Hour Banking?
28 28www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Hour Banking
• Simplify and streamline accounting and reporting
• Eliminate complexity around taking proper fringe credit
• Alleviate volatility in workforce coming on and off of benefit;
improving employee relations
• Accommodate the challenges of seasonality
• Reduce COBRA exposure for employees and the employer
29 29www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Hour Bank Example for John Doe
Month
Worked
Month
Benefit
Provided
Hours
Worked
Hourly
Rate
Contribution
Required
Hours of
Credit
Required
Depleted
From
Hour
Bank
Hour
Bank
account
June Aug 160 $1.00 $160 -130 0 30
July Sept 180 $1.00 $180 -130 0 80
Aug Oct 100 $1.00 $100 -130 30 50
30 30www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Bank Accounting Helps
• Employees may accumulate hours of work credit for excess hours worked
• Avoids possible ineligibility under traditional programs
• Protects employees from layoffs, inclement weather, etc.
• Allows employees to bank months of health care
• Allows employer to pay for actual hours worked
• HRA can be used for residual balances
• Retirement plan can be used for overflow when banks are at their max
31 31www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
What is Acceptable Coverage?
Limited medical or “mini-med” coverage is not ACA compliant
32 32www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Who is Subject to the Penalty?
33 33www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Union Employees & Multiemployer Plans
• Union employees are treated no differently than non-union
employees in determining the number of full-time employees
of an employer, and whether ACA applies to the business.
• Employers who contribute to union multiemployer plans which
provide minimum value and are affordable will not be subject
to the tax for failure to offer coverage to those union
employees.
• The determination of whether the employee portion is
affordable (does not exceed 9.5% of pay) is based upon the
actual pay reported by the employer or hourly rate of pay
under the collective bargaining agreement.
• Further IRS guidance is expected in the future.
34 34www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Transition Rules
• The first year a business is subject to the ACA rules as a
“Large Employer”, the employer will not be subject to tax for
the first 3 months (until April 1st) for lack of coverage (with
some exceptions).
• Employers may use 6 consecutive months (rather than a full
year) to determine whether they meet the “Large Employer”
definition (over 99 full-time employees) for the 2014/15
determination period.
• If an employer currently offers health insurance for workers,
and has a fiscal year plan that was in place in 2012, then in
general the rules for ACA do not apply until the first day of the
2015 fiscal plan year (rather than January 1st).
35 35www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Employee Retention Studies
• Employers consistently underestimate employee perceptions
of value:
•
• Employees who are very satisfied with benefits are nearly 3x
as likely to say they are satisfied with their jobs and less likely
to plan to leave.Source: 10th Annual MetLife Study of Employee Benefit Trends
36 36www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Offering Coverage Not Offering Coverage
• Field workers often represent better risk & a healthy
workforce is more productive• Bids may then be less competitive and / or profits impacted
• Dollars are invested in employees as opposed to paid as
taxes to the government
• Miss out on tax deduction for employer / fringe
contributions
• Employers can point to ACA as clear reasoning for taking
fringe out of wages and open the door for full benefits
offering
• Penalties are not tax deductible and fringe dollars cannot
pay for them
• Payroll burden is greatly reduced, bids can be more
competitive and the company is likely more profitable
• Limited medical or “mini-med” coverage is not ACA
compliant
• More government agencies and ordinances are looking to
require it• Weakens private sector healthcare system
• “Credible” risk status enables more options for the future • Business growth, continuity and reputation at risks
• Tax credits are available to certain small businesses so have
the fringe purchase coverage, file for and use them• Compromises recruiting & retaining top talent
• Employees will have to fend for themselves in the
exchanges or find employers that offer it
Offering Coverage VS Not Offering Coverage
Paying fringe as wages is already expensive and ACA adds another $2000-$3000 per employee not covered
37 37www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Not Going to Offer Coverage?Your Employees Will Pay for it.
• HRA, Section 125 and FSA need an employer to sponsor!
• Penalties start for individuals in 2014 and increase through
2016
• Individual coverage can be more expensive particularly
without a subsidy and paid after-tax
• Employee could have fringe paying for coverage with FICA
and income tax free dollars
• Marriage “penalty” for subsidy
• Many will not qualify for a subsidy
38 38www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Not Going to Offer Coverage?Your Employees Still Need It.
• Will “figure out” the exchanges for themselves
• Employer pre-tax programs will not be available
• Exchange products have very narrow networks
• Exchange products generally have very high deductibles and
out of pocket maximums
• Rating process for large groups vs. community rating and
impact on premium / rates
• Limited medical or “mini-med” coverage is not compliant
• Employees will feel compelled to find union or employer
provided benefits
39 39www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Which Employees Will Qualify for a
Subsidy?
• Individuals that have minimum essential coverage (MEC) via
their employer are not eligible
• Qualify when income level is between 100% and 400% of the
Federal Poverty Level (“FPL”)
• Anyone making over 400% of the FPL bears the full cost of
coverage via the exchange i.e. no subsidy is available
• “Marriage penalty” e.g. two singles can qualify at $33,510
each, but not as a married couple
Check out the link below for a calculator:http://healthreform.kff.org/subsidycalculator.aspx
40 40www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Federal Poverty Levels & Subsidies
2013 Poverty Levels 100% of FPL 400% of FPL
Single $11,490 $45,960
Two Person $15,510 $62,040
Family of Four $23,550 $94,200
AK & HI are higher.
41 41www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Annual Employee Tax Impact
2013 Single Tax Rate, with one exemption and standard deduction.
Fringe in Paycheckv
“Bona Fide” Fringe Plan
Base wage $35,000 Base Wage $35,000
Fringes $7,750 Gross Wages $35,000
Gross Wages $42,750 Federal Taxes ($3,304)
Federal Taxes ($4,991) Net Wages $31,696
- - Fringes $7,750
Total Wages $37,759 Total Wages & Benefits $39,446
42 42www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
43 43www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Challenges with Exchanges
• Coverage is not free and many
will not qualify for subsidies
• Only way an individual can get
the subsidy is to enroll in the
exchange
• “Bronze, Silver Gold and
Platinum” plans cover 60-90% of
costs
• Rating issues – 3:1 premium
differential for age
44 44www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Strategic Business Considerations• Leverage the fringe dollars for health benefits
• Cost Reduction Strategies
– Track premium dollars via hour banking by the hour and not
monthly
– Leverage consumer driven plans – HDHP’s
– Prevailing Wage compliant HRA
• Build inventory i.e. bid and win more while increasing profits
• Must get covered and credible – virgin or groups on limited medical present underwriting challenges
• Process for covering and onboarding new employees for newly awarded contracts that take you above 50 FTE’s? (100+ in 2015)
• How to contain costs and stabilize or reduce rates? Does the inclusion of your field workers lower your risk profile?
• How to remain in compliance? How much will it cost me?
• Do I partner with a generalist or a specialist?
45 45www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Strategic Business Considerations• Limited medical does not comply with PPACA after 1/1/2014
• Taking good care of key employees – reputation? Union
pressures? Message GC’s can send to subs?
• Competition – large & small employers – what will they do to
compete?
• Bidding 2-3 years out – assuming what costs?
• Discrimination rules limit coverage disparities & carve outs
46 46www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Managing Employee Objection
• Employee objection to employer provided benefits over fringe
as wages largely mitigated
• Message and Talking Points for Offering Benefits:
• The federal government and healthcare reform law is requiring it.
• Contracting agencies and certain local ordinances are beginning to look
closer for it in the bid process
• The fringe is an employer contribution, not “the employees’ money”
• Competitors that offer benefits will likely have lower bids
• Lowest bidder wins on government work
• Prevailing wages are generally higher than those on private work
• Employees greatly reduce their tax burden
47 47www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Tools to Support Contractors
48 48www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Single Source Administration
• One partner to administer and manage a complete benefits
array
• Major medical, dental, vision, life, disability, critical illness,
HRA, EAP, retirement, etc.
• Holistic employee communications
• Prevailing wage, PPACA & ERISA compliance over all
programs
• Detailed reporting for all aspects of your benefit strategy
• Opportunity to offer employees the best array without the
added burden to you or your staff
49 49www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Total Fringe Hourly Breakdown
• Keep it simple and efficient
• Remaining fringe dollars can be funneled to retirement or HRA
• HRA can be instrumental in health plan design & cost structure
• This type of approach can be set up & managed entirely online
Fringe rate $15.00 v Fringe rate $15.00
Medical single $2.00 Medical family $4.00
Vacation $1.00 Vacation $1.00
Apprentice $.25 Apprentice $.25
Retirement $11.75 Retirement $9.75
50 50www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Compliance
Work with benefits partners that offer this value as a part of their
standard solution.
51 51www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Wellness
HealthCare Reform allows for employer grant money when Wellness
Programs are offered. As preventive care is required & is cost free, this
is one key way to control current and future costs:
• Leverage your Carrier Partners
– Carrier Websites – free and useful tools for Employer and
Employees
– Built-In Carrier Wellness programs e.g. UHC Simply Engaged
– Leverage 3rd party wellness services e.g. Virgin HealthMiles
• Employer Sponsored Contest
• Biometric Screenings
• Evaluate claims reports (large groups)
• Create a Culture of and Competition for Wellness
52 52www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Benefits of Utilizing a Trust
• Satisfies one of the key DOL bona fide benefit criteria for
government contractors
• Fully insured benefits
• Advantages of a larger pool in the underwriting process
• Can obtain coverage for virgin groups or those on limited
medical
• Stabilizes cash flow and lowers renewal risk
• 3rd party trustee provides fiduciary risk protection
53 53www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Q & A
What next?
54 54www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
More Questions?
Adam Bonsky – EVP Government Markets
(512) 827-5300
Steve Slade – Director, Defined Contribution Plans
(512) 827-5313
Henry Beceiro – BB&T CEBS
(858) 875-5407
55 55www.conexpoconagg.com brought to you by Fringe Benefit Group® © 2014
Appendix
• Source: IRS Notice 2014-82; IRS Final Regulations, “Shared Responsibility for Employers Regarding Health Coverage, February 12, 2014.”
https://federalregister.gov/a/2014-03082