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American Benefits Council Comment Letter to IRS on Shared Responsibility for Employers Regarding Health Coverage (Code Section 4980H) (PDF)
American Benefits Council Link to more items from this source
[Opinion]
June 16, 2011

9 pages. "[W]e believe employers should [be permitted to] retain discretion not only to decline coverage to appropriate categories of employees in the entirety; they should also be able to provide different levels of coverage so long as the coverage meets the standards set forth in Code section 4980H.... We urge the IRS to issue guidance excluding all seasonal employees (i.e., employees working less than 6 months per year), contract employees, daily employees, and temporary employees from the definition of full-time employee."

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