As we’ve previously discussed, the IRS started issuing Letters 226J in late 2017. It continues to send these letters to employers each year proposing that the employer owes an Employer Shared Responsibility Payment (ESRP) for certain full-time employees based on the IRS’s understanding that “full-time employees” obtained premium tax credits to purchase individual health insurance on a health insurance exchange, and the employer’s health insurance was either unaffordable, did not provide minimum value, or not offered to enough full-time employees.