Frank Morris, Jr., a Member of the Firm in the Labor and Employment, Employee Benefits, and Litigation practices, in the Washington, DC, office, and Adam Solander, an Associate in the Health Care and Life Sciences practice, in the Washington, DC, office, co-wrote an article titled "Unforeseen Consequences of the ACA." (Read full version — subscription required)
Following is an excerpt:
The recent shared responsibility proposed regulation under the Affordable Care Act incorporated previously released guidance, with a few notable exceptions. While important to note, these exceptions are perhaps less significant than the release of proposed rule itself as its release started the one-year clock for employers to implement workforce management in preparation for the shared responsibility requirements.
Employers should proceed with caution, however, as workforce management efforts could have unforeseen impacts. Accordingly, it is important that employers take steps now to mitigate such effects and ensure compliance with the many new requirements of the ACA.
