If I have a large employer that renews May1st and only covers 47 employees currently ( carve out) but has 80 additional fulltime employees when must the large employer offer coverage to these additional employees, May 1st or Jan 1st 2014 ?
I've been waiting, Todd...for someone else to answer your question!
I believe the answer will have to be 1/1/2014, because I don't think that the discrimination rule or the penalty for not offering minimum essential coverage to your employees can be delayed until the group's renewal date. The law says that minimum essential coverage must be offered to at least 95% of the full-time eligible employees, so I don't think they can escape the $2,000 penalty per f/t ee that way.