Additional delays for Large Group Employer Mandates

The Federal Government announced on February 10, 2014, that it will delay enforcing certain provisions of the Affordable Care Act (ACA).  The delays affect the employer shared responsibility requirement for groups with 50 to 99 eligible employees, as well as groups with 100 or more employees.

50 to 99 Groups
Employers with 50 to 99 eligible employees will have until their first plan year on or after January 1, 2016 to provide employees who work more that 30 hours a week with healthcare coverage that meets minimum value and affordability rules.

100+ Groups
While the Federal Government had already delayed the coverage requirement for 100+ groups until 2015, these groups will now only have to cover 70% of their eligible employees in 2015.  The earlier 95% coverage requirement is now delayed until 2016.

Please note that Employers with plan years that start after January 2, 2014, will not be subject to compliance requirements until the start of their plan years in 2015.

The updated regulations also provide clarification regarding how full-time status should be calculated for certain categories of employees and occupations.  Some key categories include:

• Volunteers:  Bona fide volunteers for government or tax-exempt entities (volunteer firefighters or emergency responders) will not be considered full-time employees.
• Educational employees:  Teachers and other educational employees will not be treated as part-time for the years simply because their school is closed or operating on a limited schedule during the summer.
• Adjunct faculty:  Adjunct faculty can receive credit for two hours and 15 minutes of service per week for each hour of teaching or classroom time.