Your Company Is a ‘Large Employer’ Under the Affordable Care Act—Now What? Requirements for Coverage and Potential Penalties


The Affordable Care Act (the ACA or the Act) requires ‘‘large employers’’ (90 DLR I-1, 5/9/14) with 50 or more full-time employees to offer health insurance coverage to their eligible employees and their dependents or face the possibility of significant penalties. For many employers, determining whether they are large employers will be a complicated endeavor; for others, it will be a straightforward one. Regardless, determining whether an employer is covered under the ACA is just the beginning of the inquiry for large employers. These employers must understand their obligation to provide ‘‘minimum essential coverage’’ that is ‘‘affordable’’ and provides ‘‘minimum value’’ to eligible employees. They also should be aware of the potential penalties for failing to fulfill those obligations, and the safe harbors that exist within the proposed regulatory framework.

I. Required Coverage -

As an initial matter, it is important to note that application of the ACA’s large employer requirements has been delayed until Jan. 1, 2016, for those with 50-99 full-time employees. All other large employers will need to comply (or face penalties) beginning Jan. 1, 2015...

Originally published in Bloomberg BNA's Daily Labor Report, 93 DLR I-1, 05/14/2014.

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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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