Mintz Levin Employment, Labor, and Benefits Advisory (04/30/2013) Alden Bianchi; Ed Lenz

When it comes to complying with the Affordable Care Act’s employer shared responsibility rules starting in 2014, staffing firms face particular challenges owing to their large numbers of variable hour and contingent workers, historically high rates of turnover, limited assignment tenure, and low take-up rates where health care coverage is offered. This advisory addresses five questions staffing firms may have about the employer shared responsibility rules: what the rules are, what the compliance challenges are, how temporary workers assigned to clients are treated under the rules, how to find a carrier to underwrite coverage, and how to satisfy the obligation to provide coverage.