WASHINGTON - NACS has joined other members of the Employers for Flexibility in Health Care (EFHC) in comments submitted to the Internal Revenue Service on the Shared Responsibility for Employers Regarding Health Coverage. The coalition supports employer-sponsored healthcare coverage.

The coalition??s letter provided "general comments on the proposed look-back/stability period safe harbor method to determine who is a full-time employee and its relationship to the calculation of tax penalties under the employer shared responsibility provision." The letter also raised "additional specific questions that we ask you to consider as you draft guidance and regulations on state health insurance Exchanges, the determination of whether employer benefits are affordable, and the imposition of tax penalties."

As a group that represents employers who create millions of jobs each year, employ a significant workforce in the US, offer flexible working environments for employees, and are a leading contributor to the nation??s economic job recovery, the coalition??s purpose in writing the letter was to share "our thoughts with the administration on provisions of PPACA that affect employers. The definition of full-time employee is of particular importance to us because of our industries?? unique reliance on large numbers of part-time, temporary, and seasonal workers with fluctuating and unpredictable work hours, as well as unpredictable lengths of service."

NACS will continue following this issue and the Treasury??s response to the filed comments as the agency drafts upcoming regulations regarding state health insurance exchanges and other employer-related health insurance regulations.