IRS Proposed Rule for Shared Responsibility for Employers Regarding Health Coverage

Monday, March 18, 2013
Federal Advocacy Resources

The National School Boards Association (NSBA) offers the following comments to the proposed rule, Shared Responsibility for Employers Regarding Health Coverage, REG-138006-12, issued by the Internal Revenue Service (IRS) on January 2, 2013. NSBA appreciates the opportunity to share with the IRS: (1) the perhaps unanticipated impact certain provisions of the proposed rule may have as public school districts across the country wrestle with questions about which service hours of various categories of staff members are to be included in the full-time equivalent employee counts for “large employer” determinations; and (2) the need for clarification in some before the rule becomes final to minimize any adverse impact on the nation’s schools and students’ educational outcomes.

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