By Benjamin J. Conley, JD
Late last year, the Internal Revenue Service (IRS), U.S. Department of Labor (DOL), and the U.S. Department of Health and Human Services (HHS) issued IRS Notice 2015-87, a series of 26 frequently asked questions (FAQs) addressing a range of unanswered questions under the Affordable Care Act’s (ACA’s) employer mandate and the so-called “market reforms.”
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While many of these FAQs simply reiterated points made in earlier agency guidance, the Notice contained guidance on a series of previously unanswered questions, such as determining the “affordability” of coverage where the employer provides a “fringe” contribution under the Service Contract Act or where the employer provides an opt-out credit for employees who decline employer-sponsored coverage. This article summarizes some of the highlights of this new agency guidance.
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