IRS provides guidance needed by employers to comply with Affordable Care Act
The IRS recently released guidance that addresses some of the very technical details employers must deal with as they implement the Affordable Care Act ("ACA"). Notice 2012-58 describes optional look-back and stability periods that may be used to determine which employees are treated as full-time employees for purposes of the employer shared responsibility penalties of ACA. The notice modifies and expands on safe harbors previously provided, and includes additional safe harbor methods employers may apply to newly hired variable hour and seasonal employees. Notice 2012-59, issued concurrently, addresses the waiting period that may be applied prior to an employee becoming covered by a group health plan, which is limited under ACA to no more than 90 days.