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Excluding Certain Classes of Employees from Your Health Plan May Increase Risk of Penalty
Warner Norcross & Judd LLPLink to more items from this source
[Guidance Overview]
Oct. 7, 2015

"Whether you use the month-to-month method or the look-back measurement method to determine who is a full-time employee, categorical exclusions of entire classes of employees from your medical plan increase the risk that you will miss your targets, especially beginning in 2016, when you'll have much less margin for error ... [C]ategorical exclusions also increase the risk of incurring the Section 4980H(b) penalty, which applies when your organization avoids the [4980H(a)] penalty but any of your full-time workers end up purchasing health insurance on the Exchange and qualifying for the tax subsidy."

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