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Abstract: 

The Affordable Care Act contains market reforms that apply to “group health plans.” Failure to satisfy the market reforms gives rise to punitive penalties. The term “group health plan” includes “employer payment plans” pursuant to which employers offer their employees health coverage by paying all or a portion of the employees’ health insurance premiums. These arrangements are common among small employers, and even small employers are subject to the market reform provisions. This article describes employer payment plans, explains the application of the market reforms to employer payment plans, and sets out the requirements for transition relief that a small employer must satisfy by June 30, 2015, in order to avoid penalties.

Keywords: IRC §4980D; IRC §105(h)(2),(3); Notice 2015-17; Affordable Care Act

Affiliations:  1: Strasburger & Price, LLP.