While the deadlines for 2016 reporting are as firm as a plaster cast, we can expect the timing for replacing ACA provisions to be as stretched out as a tight bandage. Replacement legislation and its enforcement regulations are unlikely to be ready for implementation before 2019. This should signal to employers that the internal Revenue Service is likely to enforce the Employer Mandate for at least another two years, keeping the reporting bandage painfully taut for now.
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