ACA Pay-or-play Penalty Provision Delayed for Midsize Employers Until 2016

The ACA FAQ document and timeline provide more information on this and other ACA provisions.

The employer shared responsibility, or pay-or-play penalty, provision of the Affordable Care Act (ACA) has been delayed again for midsize employers (50 to 99 full-time employees). This provision won’t take effect for midsize employers until January 1, 2016, but it will still be in effect for employers with 100 or more full-time employees on January 1, 2015. The provision was originally scheduled to go into effect for all employers in 2014.

Under the provision, employers with 50 or more full-time employees are subject to a penalty for each month in which any employee is covered by the Health Insurance Marketplace (state health insurance exchange) and receives a premium tax credit to subsidize his or her coverage, and either the employer:

1. Fails to offer full-time employees (and their dependents) minimum essential coverage under an employer-sponsored plan, or

2. Offers full-time employees (and their dependents) minimum essential coverage that—with respect to employees with the premium tax credit—is either “unaffordable” or “fails to provide minimum value”

More resources
For more on this provision and other ACA requirements, check out the ACA FAQ document and the timeline* on the Employee Benefits website. Go to Document Library > Documents for Co-ops > Insurance Plans > Health Care Reform.

*We’re in the process of updating these documents to reflect the mandate delay for midsize employers.