Overview: Employer Mandate Delay for Medium-sized Employers

Under the final regulations, applicable large employers that have fewer than 100 full-time employees (including full-time equivalent employees, or FTEs) generally will have an additional year, until 2016, to comply with the pay or play rules. ALEs with 100 or more fulltime employees (including FTEs) must comply with the pay or play rules starting in 2015…

…To qualify for this delay, an ALE must provide an appropriate certification stating that it meets the following three eligibility conditions:

1.  The employer must employ a limited workforce of at least 50 full-time employees (including FTEs) but fewer than 100 fulltime employees (including FTEs) on business days during 2014;

2.  During the period beginning on Feb. 9, 2014, and ending on Dec. 31, 2014, the employer may not reduce the size of its workforce or the overall hours of service of its employees in order to satisfy the workforce size condition; and

3.  During the coverage maintenance period (that is, the period ending Dec. 31, 2015, or the last day of the plan year that begins in 2015), the employer may not eliminate or materially reduce the health coverage, if any, it offered as of Feb. 9, 2014.

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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.