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The New Math

By Stephanie Vasconcellos

The employer mandate under the Patient Protection and Affordable Care Act (ACA), which requires large employers to provide health insurance for their full-time employees or pay a penalty, is set to take effect on Jan. 1, 2015. (A special transition rule, described below, delays the effective date until 2016 for some of these large employers.) Regulations released by the Internal Revenue Service on Feb. 12, 2014, set forth the final rules that an employer must use to determine whether it is a large employer subject to the mandate. See, 79 Fed. Reg. 8543 (Feb. 12, 2014). With just over six months to go, the time is ripe for employers to determine whether they will be considered large employers and if so, to determine appropriate next steps.

A large employer is one that employed an average of at least 50 full-time employees and full-time equivalent employees (FTEs) on business days during the preceding calendar year. That is, whether an employer is a large employer in 2015 will depend on how many full-time employees and FTEs it employed on business days during 2014. An employer must take a number of steps in order to make this determination.

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