Following the Supreme Court’s June 28 ruling that upheld the Patient Protection and Affordable Care Act of 2010 (PPACA), any employers that put health care reform preparations on hold in anticipation of the decision should take them up again.
“The message we delivered to our clients the day of the Supreme Court decision is full speed ahead,” says Andy Anderson, a partner at Morgan, Lewis & Bockius. “Some people are making the decision to postpone these tasks until after the presidential election, but that could really compromise an employer’s ability to respond in time for [2014 deadlines].”
The bulk of the law’s provisions affecting employers will take effect in 2014, but a number of requirements are right on the horizon. After the flurry of initial guidance and 2011-effective dates, many employers have relaxed a bit regarding PPACA. Kurt Lawson, a partner at Hogan Lovells, advises that employers refocus the attention they had a few years ago.
Even in advance of agency guidance on some of the rules that will take effect in 2014 and beyond, employers can and should be thinking about them and planning for them at a high level.