The Obama administration's July 2013 announcement, delaying enforcement of the employer mandate under the Affordable Care Act by one year, has affected not only when employees must be offered health insurance coverage but also the period for determining who a full-time employee is for purposes of that obligation. This article explores how the delay affected those determinations.

The ACA employer shared responsibility provisions (also called the "play-or-pay" rules) provide that, after Dec. 31, employers must offer to their full-time employees (and employees' dependents) the opportunity to enroll in "minimum essential coverage" (MEC) on the effective date. "Opportunity to enroll" does not mean employees must actually be enrolled in coverage. Rather, an employer need only make an offer of coverage. Employers generally have up to 90 days from the time of offer in which to enroll employees.

Originally published in American Staffing Association on November 1, 2013.