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The Impact of Staffing Firm Employees and Contingent Workers on the 4980H Employer Shared Responsibility Requirement (PDF)
Alston & Bird LLPLink to more items from this source
[Guidance Overview]
Mar. 9, 2015

6 pages. "This Article will describe how the Employer Mandate applies to each of various types of 'contingent worker' employees and will provide practical advice for complying with the Employer Mandate.... Even if hours are managed down to avoid the Employer Mandate, the Contracting Entity should check the terms of its plan to ensure the employees provided by the staffing firm or PEO are excluded.... [E]mployers will want to check their plan documents to ensure temporary employees are not excluded. Or if exclusion is intended, employers will want to ensure that the excluded temporary employees do not cause the plan to fail the substantially all test."

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