Insurance Broker Blog

Answers to your ACA Shared Responsibility Questions

You might have read that the IRS and Treasury issued final regulations on the Employer Shared Responsibility provisions under the ACA just a few days ago. These regulations sparked a lot of questions about how the shared responsibility provision works.

If you have questions, here’s a great resource for you to read and share with your clients. The IRS issued Q&As on this topic addressing the most common questions relating to shared responsibility under the Affordable Care Act.

We’ve summarized the key takeaways below.


Question: What is the employer shared responsibility provision?

Answer: Beginning in 2015, employers who have at least 50 full-time employees (or a combination of full time and part time that add up to 50) will be impacted by this provision. Employers who are subject to the Shared Responsibility Provisions must offer health coverage that is deemed affordable under the ACA requirements. Employers who do not comply could be required to pay the employer shared responsibility.

For a more detailed explanation to these questions, you can review the Q&A response issued by the IRS.


Question: When does this take effect? When do my group clients need to comply with the Employer Shared Responsibility provisions?

Answer: The date you and your clients should be mindful of is January 1, 2015. That’s when the provisions will be effective. What does that mean for your groups in 2014? Payments won’t be assessed for 2014…but it’s a good idea to review your group data to ensure the group is ready come 1/1/2015.


Question: What types of businesses are impacted by Employer Shared Responsibility provisions? Large? Profit? Non-Profit?

Answer: All of the above. For-profit, non-profit, large employers and government entities are subject to the provisions effective 1/1/15.


Question: What businesses are not impacted by the Employer Shared Responsibility provisions?

Answer: Employers who have less than 50 employees in a given calendar year are not subject to the provisions. Part-time employees and seasonal employees might impact the total number of employees so it’s a good idea to review the full response and requirements from the IRS.


For more answers to your Employer Shared Responsibility questions, we suggest reading the comprehensive Q&A article issued by the IRS. The article thoroughly explains the provisions and their impact to your employer group clients. The comprehensive Q&A guide has responses to 46 key items relating to the Employer Shared Responsibility provisions.

As your group’s trusted benefits adviser, this is great data to share with them…and information you’ll need to help them prepare for 2015.

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