Today the Retail Industry Leaders Association (RILA) filed a comment letter on the proposed rules regarding the employer responsibility provisions (4980H) of the Affordable Care Act (ACA). The proposed rules were issued on December 28, 2012, and are what employers can rely on now to start complying with the law.
RILA members employ 6 million Americans and offer health coverage to millions of workers and their families, and are leaders in designing plans that are customized to meet their workforces’ specific needs. RILA’s comment letter addresses issues raised in the NPRM as well as issues discussed with the White House and Departments during a meeting with our member companies in late February.
In addition, RILA formed and leads the Employers for Flexibility in Health Care (E-Flex) Coalition. The E-Flex Coalition’s letter on the NPRM, filed separately, includes comprehensive comments developed with extensive input from RILA member companies.
Both letters capture retail industry views on key issues regarding the implementation of the ACA including: the definition of a full-time employee, the affordability test and how wellness programs will be factored into the calculated, transition relief, breaks-in-service, communications with employees and employers, reporting requirements, and minimum value. The E-Flex Coalition letter was signed by 20 leading trade associations and businesses which have large variable hour workforces.
RILA Comment Letter
E-Flex Coalition Comment Letter