United Benefit Advisors Insight and Analysis Blog

Employer Considerations When Offering Health Coverage under the SCA or DBA

Posted by: Danielle Capilla    Nov 3, 2016 10:30:00 AM

Employers that are subject to the McNamara-O’Hara Service Contract Act (SCA), Davis-Bacon Act (DBA), and Davis-Bacon Related Acts (Related Acts), and who are considered an applicable large employer (ALE) under the Patient Protection and Affordable Care Act (ACA) must ensure that they meet the requirements of all three acts, despite the fact that the interplay between them can be confusing and misunderstood. The Department of Labor has provided guidance for these employers based on two U.S. Department of Labor (DOL) documents: its December 28, 2015, Notice 2015-87 (DOL Notice) and its March 30, 2016, All Agency Memorandum Number 220 (DOL Memo).

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Topics: ACA, PPACA, employer shared responsibility, Danielle Capilla, applicable large employers, McNamara-O'Hara Service Contract Act, DBA, wage and fringe benefit requirements, Davis-Bacon Act, SCA