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The 2015 Employer Mandate Is Here

By Jennifer S. Kiesewetter

The year 2015 is here ' in fact, the first quarter of 2015 has already flown by ' and so is the Affordable Care Act's (ACA) employer “play or pay” mandate, which has been delayed, in total or in part, twice. On July 2, 2013, the Administration delayed the employer mandate for employers with more than 50 employees until 2015. Then on Feb. 10, 2014, the Administration extended time to provide health insurance to full-time employees to certain employers . Under the February extension, employers with 50 to 99 employees will have until 2016 before the federal penalty kicks in for not providing health insurance to full-time workers. Further, the February extension granted some relief to large companies, in that it stated that companies with 100 or more employees need only offer coverage to 70% of full-time workers in 2015, and then to 95% of full-time workers in 2016 and beyond before the federal penalties kick in.

Now, the first quarter of 2015 is upon us and the employer mandate was immediately effective as of Jan. 1 for calendar year plans for large employers. Those with fiscal plan years may have until the first day of their 2015 plan year to satisfy the mandate, if certain requirements are first satisfied. For purposes of this article, large employers with calendar year plans will be the focus for ease of discussion and applicability.

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