This blog post was authored by Heather DeBlanc

The Department of Treasury announced on July 2, 2013, that it will delay the effective date of the employer shared responsibility provisions of the Patient Protection and Affordable Care Act until 2015. 

These provisions, which expose a large employer to penalties for failing to offer affordable coverage to substantially all full-time employees, was previously scheduled to take effect January 1, 2014. 

The Obama Administration announced that due to the complexity of the requirements, more time is needed for effective implementation.  Formal guidance from the Department of Treasury is expected next week.  It is anticipated that it will simplify reporting requirements and describe the transition to allow employers to make health coverage affordable and accessible for employees.  For more information, see http://www.treasury.gov/connect/blog/Pages/Continuing-to-Implement-the-ACA-in-a-Careful-Thoughtful-Manner-.aspx.

Employers who have already adopted a Look Back Measurement Method Safe Harbor should continue to implement the safe harbor during 2014 in order to better prepare for 2015.  Those who have not adopted the Look Back Measurement Method Safe Harbor should start assessing their workforce and health plans and take steps toward implementation.  Although the delay in implementation will likely be welcome news for large employers as they prepare to comply with the complexities of this new law, employers should take advantage of this additional time by adopting safe harbors, preparing for reporting requirements and training personnel.

We will continue to provide you with updates as new developments unfold.