"[T]he employer shared responsibility and reporting requirements remain fully applicable... Penalties applicable to employers for failure to report are in addition to other ACA noncompliance penalties and are two-fold, including assessments for both a failure to file correct returns with the IRS and a failure to provide a required statements to employees.... An employer knows from the outset if it sponsors a self- funded group health plan, but whether the employer is an ALE is a determination that must be made on an annual basis.  MORE >>