As part of the Employers for Flexibility in Health Care (EFHC) coalition, ABC submitted comments April 5 to the U.S. Department of Labor on the Patient Protection and Affordable Care Act (PPACA) to offer its suggestions on ensuring employer-sponsored coverage remains a competitive option for all employees, whether full time, part time, temporary or seasonal. For the past year, EFHC has participated in numerous meetings with the Obama administration and has consistently advocated for the employer provisions in PPACA to be examined as a whole. EFHC has pointed out that the new requirements have significant consequences for employers and their ability to maintain flexible work options and affordable health coverage for their employees. In its April 5 comments , EFHC specifically addressed the proposal for newly hired employees; the determination of full-time employee status; coordination of look-back with the 90-day waiting period; coordinated reporting mechanisms; and the affordability of safe harbor and use of current wages. EFHC also expressed concern that formal guidance or rules on employer shared responsibility requirements have not been issued, stating, “Our members and companies are growing concerned that if they do not have sufficient regulatory guidance soon, they will not be able to conduct the necessary budget and planning processes to comply with the implementation deadline of 2014.” The lack of formal guidance and rules led the coalition to support the Department of Treasury’s acknowledgement in an Aug. 17, 2011, proposed rule that transition relief may be essential to preserving employer-sponsored coverage as the new requirements under PPACA take effect in 2014. “EFHC strongly encourages the administration to delay the implementation of penalties until 2016 to allow time to evaluate at least one year of data and provide time for employers to adjust their plan designs as needed,” the comments said. For more information on the FAQs and the coalition’s previous comments, visit the past Newsline article . To see more of ABC’s comments on the health care law, visit the health care reform section of the ABC website .