The Affordable Care Act—Countdown to Compliance for Employers, Week 17: Cherry Bomb in the Gold Fish Pond, or Third-Party Staffing Arrangements and “Offers of Coverage by Unrelated Employers”
With two seemingly simple and straightforward definitions in the final regulations implementing the Affordable Care Act’s pay-or-play rules—i.e., definitions of “employer” and “employee”— the Treasury Department and IRS have raised a host of concerns for third party staffing arrangements. (The IRS has provided a useful summary of the final regulations in a set of Questions…