Applicable large employers – those with 50+ full-time employees (ALEs) – under the Affordable Care Act (ACA) must satisfy the law’s “employer mandate,” meaning that they may be assessed penalties for:
- Failing to offer minimum essential coverage to full-time employees and their dependents
- Offering eligible employer-sponsored coverage that is not affordable or does not provide minimum value, as defined under implementing guidance
The IRS rules under the ACA teem with definitional challenges for the terms “applicable large employer,” “minimum essential coverage,” “full-time employees,” “affordable” and even “dependent” and I won’t elaborate on the details here.
I want to focus here on what I consider to be the typical ALE that regularly uses the services of a staffing firm to fill some positions or even whole departments and the effect of those workers on the ALE’s compliance with the ACA. Continue Reading