Pay or Play Penalty: 2015 Transition Relief Overview

Effective Jan. 1, 2015, the Affordable Care Act (ACA) imposes a penalty on Applicable Large Employers (ALEs) that do not offer affordable, minimum value coverage to full-time employees (and their dependents). These penalties are often referred to as the “employer shared responsibility” or “pay or play” rules.

On Feb. 10, 2014, the Treasury released final regulations implementing the ACA’s employer shared responsibility rules. The final regulations include a number of transition relief provisions for 2015 that apply to certain ALEs.

The following provides a high-level overview of the transition relief available to certain ALEs in 2015.

2015 Transition Relief Chart


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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.