WorldatWork, a nonprofit human resource association, turned in a comment letter to the Internal Revenue Service Department of Health and Human Services regarding the proposed regulations to oversee employers' shared responsibility or pay-or-play provisions as part of the Patient Protection and Affordable Care Act.

Members of WorldatWork created a focus group to contribute to the association's letter. In accordance with PPACA, all large employers must offer affordable health care coverage to their employees as well as their dependents or pay penalties starting in 2014. Among the top concerns are surrounding the definitions and measurements of new full-time employees, the look-back measurement method for new variable hour and seasonal employees, and employees rehired following termination of employment.

"Due to the unique nature of companies, work forces, industry sectors and business models, it's very difficult for one-size-fits-all definitions and recommendations to work for all organizations in terms of counting hours and determining eligibility for health care benefits," says Cara Woodson Welch, vice president of policy and public affairs of WorldatWork.