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Health Care Reform: College & University Group Submits Comments on Application of Pay or Play Rules in College & University Setting

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March 2013

On March 18, the American Council on Education submitted a comprehensive comment letter on the application of the Affordable Care Act’s “pay or play” rules to certain groups of employees that are unique to the college and university setting (such as adjunct faculty and student employees). Although we are still waiting for clear guidance from the IRS on these issues, our college and university clients and friends may want to consider some of the items and suggestions that are raised in ACE’s comment letter. In particular, it is not clear that the IRS will issue any further guidance on these issues before the 2014 effective date, so college and university employers should consider this commentary when determining how to reasonably comply with the rules. 

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