Human Resources
Aon Hewitt Submits Comments on Shared Responsibility for Employers Regarding Health Coverage

Aon Hewitt Submits Comments on Shared Responsibility for Employers Regarding Health Coverage


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On March 18, 2013, Aon Hewitt submitted comments to the Internal Revenue Service (IRS) in response to a proposed rule related to the shared responsibility for employers regarding health coverage, as implemented by the Patient Protection and Affordable Care Act (Affordable Care Act). The proposed rule was published in the Federal Register on January 2, 2013.

In the comment letter, Aon Hewitt discusses:

  • The optional look-back measurement method;
  • Employees resuming service after an absence;
  • The issue of actual terminations and rehires within 26 weeks;
  • Section 4980H(a) relief for failure to offer coverage to a limited number full-time employees;
  • The affordability safe harbors for Section 4980H(b) purposes, including a "prior year W-2 wage" safe harbor recommendation;
  • The affordability safe harbor and wellness credits/penalties;
  • The definition of applicable large employer member;
  • The definition of full-time employee for employees historically not paid on an hourly or salaried basis; and
  • Plans with fiscal year plan years.

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