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The ACA Employer Mandate and the Unionized Workforce
Mintz Levin 
[Guidance Overview] Feb. 11, 2013
"[Code section 4980H, the employer mandate,] is geared towards companies that sponsor the 'single employer' health plans in which their employees participate. These employers have control over plan design, costs, and waiting periods, and may make adjustments to their plans as need be to satisfy 4980H. 4980H does not fit so well with many employers that employ union workers.... In the preamble to the recently proposed 4980H regulations, the Internal Revenue Service acknowledged some of these unique features by providing a transition rule to apply to Multiemployer Plans through 2014."
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