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Agencies Provide Guidance on Determining Full-Time Employees and 90-Day Waiting Period


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Date: September 10 2012

The Internal Revenue Service (IRS), Department of Labor (DOL), and Department of Health and Human Services (HHS) issued two pieces of guidance on August 31, 2012, to guide employers in implementing provisions of the Patient Protection and Affordable Care Act (Affordable Care Act). IRS Notice 2012-58 addresses methods for determining who is a full-time employee and was issued by the IRS only. IRS Notice 2012-59 (DOL Technical Release 2012-02) addresses the 90-day waiting period and was issued jointly by all three agencies.  The Aon Hewitt bulletin, which provides a summary of both Notices, is available here.   



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