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ACA Penalty Risk When Dropping Coverage for Unpaid Premiums During Leave of Absence
Graydon Head & Ritchey LLPLink to more items from this source
[Guidance Overview]
Dec. 2, 2015
"The IRS treats an employer as having made an offer of coverage to a full-time employee if coverage terminates because the employee fails to timely pay the premiums. Effectively, you can terminate the employee's coverage without fear that the employee will go to the exchanges, receive a subsidy, and trigger the penalties. However, just like COBRA, the IRS treats a premium payment as timely if paid within a 30-day grace period, and it is considered paid on the date the employee mails the check."

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