Affordable Care Act guidance regarding full-time employee status

The Internal Revenue Service (“IRS”) recently issued Notices 2012-58 and 2012-59 (Notice 2012-59 was issued in conjunction with the U.S. Departments of Labor and Health and Human Services), which collectively implement requirements under the Patient Protection and Affordable Care Act (the “Affordable Care Act”). The Notices provide guidance regarding how to determine the full-time status of employees for purposes of the employer shared responsibility rules and the 90-day waiting period requirement.