HC 4420 University of Denver ACA Enforcement Compliance Letter

I’m working on a public health exercise and need an explanation and answer to help me learn.

ACA Enforcement: Will They Be Able to Comply?

You work for Big Corporation USA in the compliance department located at headquarters in Big City, USA.  Big Corporation has over 16,000 employees worldwide, and since 2015 has been outsourcing US jobs at an increasing rate to independent contractors.  These independent contractors work on average 40 hours per week, and must follow Big Corporation’s rules and regulations. Big Corporation has also been steadily converting over certain positions in its US satellite offices to seasonal employees. The contractors, including seasonal workers, are employed by “Easy Staffing, USA.”  Big Corporation does not offer the contractors or seasonal workers any benefits. Easy Staffing offers the contractors and seasonal workers insurance coverage for major medical, but the premiums are steep and the deductibles are high. The major medical has limited coverage. You get an email from the CEO stating “attached is a Letter 226J from the IRS.  Can we get around this? We have no penalties so far, so what is the big deal?” What do you write back?  Back up your email with two readings from this week. 

Churning, Network Adequacy

Rural Hospitals Demonstration Program

Dickson, 13 Hospitals Join CMS’ Rural Pay Experiment (2017), http://www.modernhealthcare.com/article/20171121/NEWS/171129970 (Links to an external site.)

Rural Hospital Demonstration Extension Act (Congressional Record showing bill did not pass), https://www.govtrack.us/congress/bills/114/s607 (Links to an external site.)

Employer Shared Responsibility


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