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Technical Pitfalls Pervasive with Look Back Measurement Method Rules
Health Care Attorneys P.C.Link to more items from this source
[Guidance Overview]
Oct. 26, 2015
"[T]he final regulations provide examples of look back measurement method time frames that do not conform to the rules for each date of the year.... [W]hile the specific example provided in the final regulations is compliant, an employer using the example's Initial Measurement Period could be penalized for hiring an employee on seven dates in the calendar year. This could subject the employer to a penalty under section 4980H for each full calendar month during the Initial Measurement Period and associated Administrative Period.... [T]he third example creates a similar issue[.]"

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