As we move through the 4th Quarter of 2014 and close in on Halloween and the November 4 mid-term elections (which may be equally frightening for us all), the big news is that the employer mandate has not been delayed. As of today, the mandate is scheduled to take effect starting in January for employers with 100 or more full-time employees, including full-time equivalents. While many had predicted further delay, the probability of delay is decreasing with each passing day. In my opinion, if the mandate is not delayed between the elections and the start of the Health Insurance Marketplace open enrollment period on November 15, it will not be delayed.
Without question, the best plan for large employers is to continue to prepare to comply, and to consider any potential delay or changes to be a backup solution. Large employers need to confirm whether or not the mandate applies for 2015, and if so, to identify all 30+ hour employees that must be offered qualifying coverage at the 2015 effective date.
Linked here is an updated one-page summary of the mandate in case helpful to you or your team. Further details are available upon request, and we continue to offer ACA advising and education sessions as part of our compliance services platform.