As you might know, the guidance associated with the employer pay or play provisions (employer fair share) will apply to common law employees.
Determining who is a common law employee can be a big deal for this reason alone - but it also carries with it a host of other legal implications (like W2 reporting).
Many public organizations are asking if coaches are common law employees. Often their pay is called something else like a stipend or a fee. While not direct legal guidance, the IRS seems to think these are typically individuals who are under the direction and control of the school employer and thus may rise to a common law employee.
If you need help figuring out who your employees are for the Affordable Care Act, please contact Kinney and Larson.