Another Delay Announced in Mandatory Health Coverage for Larger Employers

February, 2014

On Monday, the Obama administration announced another delay in the implementation of a key piece of the Affordable Care Act - the requirement for some larger employers to provide affordable and acceptable health insurance to their employees.

Originally, this requirement was to be in force for the 2014 calendar year, but was previously delayed until January 1, 2015. This most recent announcement now delays the coverage requirement for those with at least 50 but fewer than 100 employees until January 1, 2016. For those with 100 or more employees, the mandate remains in place for the 2015 calendar year.

For employers that are either brand new or have a varying employee count, Monday’s ruling also gave guidance regarding the measurement of the number of employees:

If an employer is in their first year of business, they will be allowed to make a reasonable estimate of their annual employee count to determine ‘pay or play’ eligibility. If in their second year of business, but don’t have a full year to look back on, they can rely on 3 months’ worth of data to determine their employee count for ACA purposes.

Finally, for those employers with workers whose employment status may vary from month to month, an important break-in-service requirement was reduced, meaning that employers can consider a returning employee that has not worked for that employer for at least 13 weeks can then be considered a new employee for the purpose of meeting initial health care eligibility requirements once again. Certain exemptions for educational employers apply.

For questions surrounding these items or other topics related to the Affordable Care Act, contact Cascade today.


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