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What We've Got Here Is a Failure to Communicate: Reporting Offers of Coverage for Common Law Employees
Benefits Bryan CaveLink to more items from this source
May 1, 2015

"Under the Affordable Care Act (ACA), employers are required to report on the offers of coverage made to their common law employees.... if an offer of coverage is made on behalf of a staffing company or multiemployer plan, how will the employer have this information? ... [T]he rules allow the multiemployer plan to report on the employers behalf ... [but] there is no similar rule for staffing companies.... Staffing firms and multiemployer plans may or may not be aware of these reporting rules, or of the scope of data needed for reporting. If they aren't, they will need some lead time to be able to assemble the data in time for reporting in early 2016."

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