Start Counting! Employers and Group Health Plans Must "Count" Themselves into Compliance with the Affordable Care Act in 2013 and 2014

One theme weaving its way through the multitude of Affordable Care Act (ACA) guidance released over the past few years is this: Employers and group health plans must learn to count, and they must learn to count the "ACA way." Several provisions with effective dates starting in 2014 require employers to know the size of their workforce. Similarly, several provisions with effective dates starting in 2013 and 2014 require group health plans to know the number of lives covered by the plan. In all instances, there are specific rules regarding when employees and plan-covered lives should be counted and how they should be counted.

The following chart identifies the ACA provisions affected by an employer's number of employees or a plan's number of covered lives. Employers and group health plans should study this chart to identify what and when to start counting employees and covered lives to ensure compliance with the ACA. Click on the image for a larger versiom of the chart.

See the coming editions of the Benefits Broadcast Newsletter for an overview of the rules for identifying full-time employees, the ACA 90-day waiting period, and additional updates about compliance with the ACA.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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