Kilpatrick Townsend

Final Employer Penalty Regulations

As you no doubt seen in this morning’s paper, the final employer penalty regulations have been released.  We plan on providing a one hour teleconference to brief our clients on these daunting and important regulations (all 227 pages) in the next few weeks.  So, stay tuned for an invite.  In the meantime, here are a few important highlights: 

  • Large employers with 100 or more employees only have to provide coverage to 70% of their full-time employees for 2015.  Beginning in 2016 and beyond the percentage increases to 95% of full-time employees.
  • Employers with 50-99 employees do not have to comply until 2016.
  • Special look back transition rules apply to 2015.
  • The application of the look back method to some employee groups and the monthly method to other employee groups is clarified.
  • Certain volunteers are excluded from the definition of full-time employees.
  • Special rules are added for school teachers to determine full-time status.
  • Seasonal employees working 6 months or less will not be considered full-time.