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Aon Hewitt Submits Comments on Health Coverage Affordability Safe Harbor for Employers

On December 13, 2011, Aon Hewitt submitted comments to the Internal Revenue Service (Notice 2011-73) in regards to the Health Coverage Affordability Safe Harbor for Employers (Section 4980H). The Notice, published on September 13, 2011, requested public comment on a proposed affordability safe harbor for employers under the shared responsibility provisions included in the Patient Protection and Affordable Care Act (Affordable Care Act) that will apply to certain employers beginning in 2014.

In the comment letter, Aon Hewitt responds to the following issues raised in Notice 2011-73:

  • Whether or how wages and employee contribution amounts would need to be determined for employees who are employed by an employer for less than a full year, who move between full-time and part-time status, situations in which the plan is not a calendar year, and other special circumstances;
  • Whether there are other possible safe harbor methods for determining the affordability of coverage under an employer-sponsored plan for purposes of calculating an employer's potential assessable payment under 4980H(b);
  • How to coordinate any affordability safe harbor with the full-time employee look-back/stability safe harbor described in Notice 2011-36; and
  • Clarification related to dependent coverage.

The full comment letter is available below.

Aon Hewitt Submits Comments on Health Coverage Affordability Safe Harbor for Employers