Human Resources
The Washington Report

The Washington Report

August 22, 2018


House Adjourned for Summer; Senate Returns

The House is on summer recess and will return to the Hill after Labor Day. The Senate reconvened on August 15 after an abbreviated August recess.


IRS Publishes FAQ on Employer Shared Responsibility Provisions and AHPs

On August 20, 2018, the Internal Revenue Service (IRS) published frequently asked question (FAQ) #18, which addresses employer shared responsibility provisions and Association Health Plans (AHPs). The FAQ is found on the IRS website: “Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act.”

FAQ #18 addresses whether or not the shared responsibility provisions apply if an employer who is not an applicable large employer (ALE) offers coverage through an AHP. The IRS states that employer shared responsibility provisions do not apply if an employer that isn't otherwise an ALE offers coverage through an AHP.

IRS FAQ #18 is available here.

The AHP Definition of "Employer" final regulations, issued June 21, 2018, are available here.

Other HR/Employment

Treasury and IRS Publish Fourth-Quarter Update to 2017–2018 Priority Guidance Plan

On August 17, 2018, the Treasury and Internal Revenue Service (IRS) released the fourth-quarter update to the 2017–2018 Priority Guidance Plan. The plan contains guidance projects that the Treasury and IRS hoped to complete during the twelve-month period from July 1, 2017, through June 30, 2018 (the plan year). Most of the projects do not involve the issuance of new regulations. Rather, the projects provide helpful guidance to taxpayers on a variety of tax issues important to individuals and businesses in the form of: 1) revocations of final, temporary, or proposed regulations; 2) notices, revenue rulings, and revenue procedures; 3) simplifying and burden-reducing amendments to existing regulations; 4) proposed regulations; or 5) final regulations adopting proposed regulations.

The 2017–2018 Priority Guidance Plan contains 198 guidance projects, 30 of which had been completed before its publication. In addition to the projects on the 2017–2018 plan, the Appendix lists routine or ministerial guidance that is generally published each year. A total of 125 projects on the 2017–2018 plan, as so updated, were published by June 30, 2018. This final quarterly update includes 12 additional projects. In addition, the update reflects one project the Treasury and IRS closed without publication.

The fourth-quarter update to the 2017–2018 Priority Guidance Plan is available here.

Previous 2017–2018 Priority Guidance Plan updates are available here.

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