On April 23, MCAA testified at an Internal Revenue Service (IRS) hearing on how the agency will gauge a company's employment level threshold in 2014 for the assessment of tax penalties on employers with over 50 employees that do not offer qualifying health care coverage. MCAA was represented at the hearing by Aruna Vohra, Health Care Practice Leader at Horizon Actuarial Services, and Alan Cabral, a partner with the Seyfarth Shaw law firm. MCAA's position is that workers covered by multiemployer health care plans that meet the law's employees standards should not be included in an employer's employee count of its non-bargaining unit personnel. The employment and benefits relationship of workers in the multiemployer system warrants unique treatment as compared with employees covered or not by single employers. Apprentices, trainees, and non-bargaining unit personnel covered by health plans under multiemployer plan participation agreements also should be excluded from the employee count for any sponsoring employer in the multiemployer bargaining unit. MCAA's testimony and written comments are available at www.mcaa.org/private/labor.