The final rules include a one year delay for medium-sized employers. In 2015, the ACA’s employer shared responsibility provisions will generally apply to larger firms with 100 or more full-time employees. Employers with 50-99 full-time employees will have to comply starting in 2016. In addition, the final rules extend to 2015 a package of limited transition rules that applied for 2014 under the proposed regulations, and also include transition relief for employers that offer coverage to most, but not all, full-time employees in 2015.
The Treasury and IRS plan to issue further guidance to address remaining issues under the employer shared responsibility provisions. In addition, the Treasury and the IRS will issue final regulations shortly that aim to substantially simplify and streamline the employer reporting requirements.
We also have a Pay or Play calculator for interested employers to determine what are the implications in 2015 and 2016.