Which of Your Clients Are Subject to The ACA’s “Play or Pay” Provisions?
Which of Your Clients Are Subject to The ACA’s “Play or Pay” Provisions?February 21, 2017
Ken Ruotolo, Chief Operating Officer
Despite the intense media focus on repeal, replace and repair, the laws and regulations of the ACA are still in effect, including the Employer Shared Responsibility provisions (“Play or Pay”). Early each year, your clients should answer the following critical question: Was their count of full-time plus full-time equivalent employees 50 or more on average during the prior year?
If the answer is “yes,” then your client is an Applicable Large Employer (ALE) and must offer coverage to full-time employees or potentially incur penalties. You will want to quickly have a discussion with them about putting a plan in place.
However, if the answer is “no,” then they are not at risk of incurring penalties if they choose not to offer coverage. This includes not offering coverage during the current year even if they were an ALE in prior years.
Have your clients asked and answered that key question? If not, you may want to quickly engage in a discussion with them about the topic. For your reference, Claremont has developed a comprehensive Play Or Pay Guide for Brokers. In it you and your clients can learn how to:
- Determine if they are an ALE
- Know when, as an ALE, they must comply with the “Play or Pay” provisions of ACA
- Determine who needs to be offered coverage
- Assess whether plans provide the required benefits to comply with the ACA
- Calculate their exposure to ACA penalties
If your client determines they are an ALE for the first time, there is transition relief that permits them to not offer coverage through March of their first year as an ALE. This article provides helpful information for new ALE’s and their deadline for offering coverage.
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