On February 10, 2014, the Internal Revenue Service (IRS) released final regulations delaying the enforcement of Affordable Care Act (ACA) penalties against employers with 50-99 employees until 2016 and allowing employers to determine whether they are large employers in 2015 based on any consecutive six-month period in 2014. The regulations also exempt employers with 100 or more employees that offer insurance to at least 70 percent of their full-time employees from penalties for failure to offer coverage in 2015.
Implementation of the Affordable Care Act (ACA) continues at an accelerated pace. Some of its most important provisions for employers are scheduled to take effect in January 2015. With the force of these provisions now less than a year away, employers need to understand their impact and begin to prepare now to comply with the new requirements. To assist in this effort, we have outlined some of the questions employers will face in preparing for January 2015 and how employers may approach these questions in light of the ACA’s requirements. Note, however, that employers that self-insure are subject to an additional set of requirements not addressed here.