• Patient Protection and Affordable Care Act
  • November 19, 2012
  • Law Firm: Harter Secrest Emery LLP - Rochester Office
  • On the Friday before the Labor Day weekend, the Internal Revenue Service (IRS) issued Notice 2012-58, which establishes a safe harbor method for employers to determine which employees must be treated as “full-time” employees for purposes of the employer “shared responsibility” penalty provisions that will become applicable in 2014 under the Patient Protection and Affordable Care Act (PPACA). Simultaneously, the IRS, Department of Labor (DOL) and Department of Health and Human Services (HHS) issued Notice 2012-59 to provide temporary guidance regarding the 90-day waiting period rule under PPACA. Both Notices state that employers may rely on the guidance in the Notices until at least the end of 2014.