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Group Health Plan, Cafeteria Plan and Health FSA Nondiscrimination Theory and Practice
Mintz Levin Link to more items from this source
[Guidance Overview]
Dec. 8, 2014
"As applicable large employers grapple with the [ACA's] employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency: Do I have to offer the same group health insurance coverage on the same terms to all my full-time employees? Do I have to offer pre-tax treatment of premiums to all my employees? ... [T]heory varies widely from practice for various reasons.... [It] is entirely likely that today's answers will not be tomorrow's answers."

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