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2015 Employer Mandates For The Affordable Care Act

Effective January 1, 2015, employers with 100 or more full-time or full-time equivalent employees who do not offer affordable health insurance that provides minimum value to their full-time employees (and dependents) may be required to pay an assessment if at least one of their full-time employees is certified to receive a Premium Tax Credit in the individual Health Insurance Marketplace.

Certain employers are subject to the Employer Shared Responsibility provisions under the ACA. Under these provisions, such employers may be penalized for:

  • Not providing minimum essential coverage to their full-time employees and dependents.

  • Not providing coverage that is affordable and that provides minimum value. On February 10, 2014, the Internal Revenue Services (IRS) and the Department of the Treasury issued a final rule implementing the employer shared responsibility requirements under section 4980H of the Internal Revenue Code.

When Does The Employer Responsibility Provision Take Effect?

Although the requirements are effective, beginning January 1, 2014, overall enforcement has been delayed to January 1, 2015, with an additional enforcement delay added for employers with 50 to 99 full-time or full-time equivalent employees. For those employers, the requirements will not be enforced until plan years with effective dates on or after 1/1/16, if certain conditions are met.

Transitional relief is also available for employers with 100 or more full-time or full-time equivalent employees. For these employers who provide coverage that is affordable and meets minimum value to at least 70% of full time employees in 2015 and at least 95% in 2016 and beyond, the 4980(H) penalties will not be triggered.

For a calendar year, employers who employ fewer than 50 full-time employees and full-time equivalents in the prior calendar year are not subject to the Employer Shared Responsibility provisions.

Additional ACA Resources.

As the ACA continues to change and evolve, it is a challenge for all employers to maintain compliance. To track the latest ACA changes and information, we have provided below a number of resources for you so your staff to read.

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