Legal Briefing: Affordable Care Act Final Regulation


Aug. 5, 2014

The U.S. Internal Revenue Service issued final regulations under the Affordable Care Act and set deadlines for compliance. Large employers with 100 or more full-time or full-time-equivalent employees are required to comply with the “shared responsibility provisions” (employer mandates) of the regulations on Jan. 1, 2015, with requirements for employers with 50 to 99 full-time/FTE employees being delayed until 2016.

For purposes of compliance, regulations require that employers determine the average number of employees during the preceding year, counting both full-time employees (those employed at least 30 hours per week) and the total number of FTEs in each calendar month. New employers that reasonably expect to employ an average of at least 50 full-time/FTE employees will qualify. For 2015 only, an employer may determine whether it is a covered large employer by reference to a period of at least six consecutive calendar months in 2014. The regulations also address a 90-day waiting-period rule applicable to all group plans, which does not require an employer to offer coverage to any particular individuals or class of individuals and imposes no penalties, if an employee is otherwise eligible. 26 C.F.R. Parts 1, 54 and 301(Feb. 12, 2014). 

IMPACT: With compliance beginning as early as January 2015, employers should determine their number of employees under the regulations to determine when compliance is necessary.


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