Human Resources
Thought Leadership

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

On June 17, 2011, Aon Hewitt submitted comments to the Internal Revenue Service (IRS) in response to Notice 2011-36, which focused on shared responsibility for employers regarding health coverage (Section 4980H). IRS Notice 2011-36 was released on May 3, 2011.

Aon Hewitt's comment letter offers detailed analysis on the following questions posed in Notice 2011-36:

  • Definition of “hours of service.
  • Calculation of hours of service for non-hourly employees.
  • Look-back/stability period safe harbor.
  • General request for comments.
  • Challenge in offering coverage to certain groups of employees.
  • 90-day waiting period.
  • Dependent coverage.

The full comment letter is available below.

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