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The Final Countdown

By Timothy B. Collins and Amanda E. Layton

When the Patient Protection and Affordable Care Act (the Act) was enacted on March 23, 2010, it featured myriad new requirements for both employers and employer-sponsored group health plans. Employers began to implement these requirements in 2010, while keeping sight of the mandates that would become effective in later years. Indeed, one of the most popular components of any article addressing the Act was a timeline outlining the various effective dates for key provisions of the Act. To date, the provisions of the Act highlighted in these timelines have brought many changes; however, the year 2014 ushers in the most significant changes to date: the implementation of Health Benefit Exchanges (Exchanges) and employer “shared responsibility” provisions.

Jan. 1, 2014, has been one of the most anticipated dates under the Act due to the material changes that both mandates may bring to employer-sponsored healthcare coverage. This date is misleading, however, if employers believe that it means that they do not have to begin planning for compliance until the start of next year. Following the publication of proposed regulations on employer shared responsibility provisions by the Treasury Department and the Internal Revenue Service on Jan. 2, 2013, it is apparent that employers should begin focusing on these provisions now.

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