NAPEO: National Association of Professional Employer Organizations

Government Affairs
What We Advocate

Healthcare Reform

In March, 2010 the Patient Protection and Affordable Care Act (PPACA), as amended by the Healthcare and Education Reconciliation Act (HCERA) (collectively the "ACA"), was enacted to reform healthcare coverage. In June, 2012 key elements of the law were upheld by the Supreme Court. Implementation efforts are continuing at both the federal and state levels. NAPEO's Healthcare Reform webpages can serve as guides to understanding the law and how it may affect your business.

NAPEO Members can also find specially selected information related to PEOs on the Member Healthcare page in the Member Resource Center. If you are not currently a NAPEO Member and you would like access to member exclusive healthcare content as well as all the additional benefits of membership, please contact NAPEO's Membership Team at (703) 836-0466.

Latest News

NAPEO will be sending out emails to those who are interested in the latest developments on healthcare. The emails will contain the top news stories on healthcare for the past week and links to healthcare reports that are relevant to the PEO industry. If you would like to receive these emails, please email NAPEO's Director of Federal Government Affairs, Thom Stohler, at For the current NAPEO Weekly Healthcare Email and an archive of past emails, please click here.

The Law and Implementation
The Statute, including a summary of major provisions

The Supreme Court Decision, including links to additional commentary and analysis

Government Implementation

  • Employee Benefits Security Administration (EBSA health reform page)
  • Internal Revenue Service (IRS Affordable Care Act Tax Provisions)
  • Health and Human Services ( and its subunit The Center for Consumer Information & Consumer Oversight (CCIIO home page)
  • Guidance regarding implementation:
    • IRS Notice 2012-58 describes safe harbor methods for employers to calculate which employees are considered full-time for purposes of determining the applicability of the shared employer responsibility provisions, IRC § 4980H (also known as the play or pay requirement). A full-time employee is defined as working at least 30 hours per week.
    • IRS Notice 2012-59 provides guidance regarding the 90-day waiting period limitation imposed by § 2708 of the Public Health Services Act. Under that provision, the time before coverage becomes effective for an eligible employee cannot exceed 90 days.
    • IRS Issues Proposed Regulations for PPACA Employer 'Shared Responsibility' Provisions. Late on December 28, the Internal Revenue Service (IRS) issued proposed regulations addressing the 'shared responsibility' provisions for employers under Section 4980 of the Patient Protection and Affordable Care Act (PPACA). These provisions (commonly known as the "pay or play" mandate) require employers to offer health coverage for their full-time employees or pay a penalty under certain circumstances. Comments on the proposed regulations are being solicited by the IRS through March 18, 2013. A public hearing to discuss the proposed regulations will be held on April 23, 2013; requests to speak at the hearing and an outline of those remarks are due to IRS by April 3, 2013.

State Exchanges
Links to state exchange websites

Helpful links to state exchange information

Further information from webinars and publications:

PEO Issues
This page highlights just a few of the many issues that will be facing employers and PEOs

NAPEO Member Insights
These links to articles and other content produced by NAPEO Members provide helpful insights for PEOs and their clients:

Additional Resources
These websites provide comprehensive analysis of the ACA and its implementation:

Here are a few helpful links to general background information regarding healthcare:

  • The Kaiser Family Foundation and the Health Research & Educational Trust conduct an annual national survey of employers in order to provide current information about the nature of employer-sponsored health benefits and trends in coverage, including premiums, employee contributions, cost-sharing provisions, and other relevant information. A summary of the key findings is also available and further information can be found at the survey’s website.

State-by-State Expansion of Legal & Operational Certainty

PEO or Employee Leasing-specific registration or licensing requirement was enacted.

State law recognition generally as an employer without a registration or licensing requirement.

Pending licensing or registration legislation.






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