This morning the IRS requested public comment on the definition of a "full-time employee" for purposes of the employer penalty provisions of the Affordable Care Act.  IRS Notice 2011-36 (link below) sets forth various ways that a full-time employee can be defined under these rules and asked employers and other interested parties to submit comments by June 17, 2011.  Under the Affordable Care Act, employers with 50 or more full-time employees that do not offer affordable health coverage to their full-time employees are required to pay the employer penalty.  The employer penalty takes effect January 1, 2014 and specifically exempts small employers that have fewer than 50 full-time employees.