Affordable Care Act
Employer Provisions
Chapter 11
pp. 411 - 463
2015 National Income
Tax Workbook™
pp. 412-413
Types of Health Coverage
 Minimum Essential Coverage (MEC)
▪ Individual must have
▪ Large employer must provide to full-time EEs
 Excepted Benefits: Not = MEC
▪ Will not satisfy employer mandate
▪ Will not satisfy individual mandate
2
pp. 412-413
Types of Health Coverage – MEC





Eligible employer plans
Individual state Marketplace plans
Certain Government plans
Grandfathered plans
Coverage recognized by HHS
3
Types of Health Coverage
Excepted Benefits
pp. 413-414
 Always Excepted Benefits – listed p. 413
 Limited Excepted Benefits
▪
▪
▪
▪
▪
▪
FSA
Limited-scope dental or vision benefits
Benefits for long-term care/nursing home
Employee Assistance Program (EAP)
Noncoordinated and supplemental
Wraparound Coverage
4
Types of Health Coverage
Excepted Benefits
p. 414
 Wraparound Coverage – Pilot Program
▪ Offer coverage no earlier than 1/1/2016
▪ Offer coverage no later than 12/31/2018
▪ Coverage to end 3 years after 1st offered
▪ Annual reporting requirements
▪ Wraparound eligible individual coverage
or coverage in a multistate plan
5
Types of Health Coverage
Excepted Benefits
p. 414
 Wraparound Coverage – Individual
▪ Eligible individuals
• Cannot be in health FSA
• Limited to part-time EEs or retirees
• Can cover spouse/dependents
• ER must offer full-time EEs coverage
substantially similar to ACA coverage
6
Types of Health Coverage
Excepted Benefits
p. 414
 Wraparound Coverage –Multi-state Plan
▪ Coverage must be approved by OPM
▪ Provides benefits in conjunction w/ multistate plan
▪ In 2013 & 2014 Employer
•
•
Offered coverage substantially similar to ACA
required offers to full-time in 2015
Offered affordable, minimum value coverage to
“substantial portion” of full-time
▪ Annual employer payments for primary and
wraparound coverage ≥ 80% of 2013 or 2014 $
7
p. 415
ACA Employer Timeline -2015
 Employer & insurer reporting required
▪ All large ERs & small ERs if self-insured
 No ESRP for some ERs with 50 – 99 FTEs
 Excise tax relief
▪ Small employers through 6/30/15
▪ For health care arrangements re: 2% S
corp S/H through 12/31/15
p. 416
ACA Employer Timeline - 2016
 Employer & insurer reporting required
▪ All large ERs & small ERs if self-insured
 ESRP could apply to all ALEs
 Excise tax relief
▪ For health care arrangements re: 2% S
corp S/H if no guidance issued yet
 SHOP available to ERs with ≤ 100 FTEs
▪ 2015 PACE Act: 100 to be State decision
p. 417
Whistleblower Protection
§ 1558 of ACA expands protection to EEs who
 Received a PTC
 Provided/will provide info relating to any act or
omission employee believes violates ACA
 Testified/will testify regarding such violation
 Assisted/participate in related proceeding
 Objected to/refused to participate in activity EE
believes to be in violation of any part of ACA
p. 417
Whistleblower Protection
Prohibited Acts
 Demotion or reassignment to less desirable job
 Denial of overtime, benefits, promotion
 Harassment, intimidation, threatening behavior
 Reduction in pay or hours
 Wrongful discharge/termination
p. 417
Whistleblower Protection
Effects on Employer
 Adverse OSHA determination – reinstate, back
pay w/interest, damages, related fees
 Substantial ESRP penalty
▪ Financial reward to EE of 15% to 30% of
collected ESRP
Practitioner Note: Staff Education a Must!
p. 418
Employer Shared Responsibility Payment
(ESRP)
Applicable large employer (ALE) liable if ≥ 1
full-time employee (FT EE) gets premium tax
credit (PTC)
AND
ALE did not offer MEC to FT EEs or offers MEC
to < 95% of FT EEs and dependents
or
MEC not affordable, w/o minimum value (MV),
or MEC not offered to FT EE getting PTC
2015 Transition Relief pp. 418-419
50-99 Employee Relief
 No potential ESRP in 2015 if
▪ FTEs in 2014 were at ≥ 50 < 100
▪ No reduction in # of EEs or EE hours
from 2/9/14-12/31/14
▪ No elimination or material reduction in
coverage offered 2/9/14-12/31/14
 Applies to plan years beginning in 2015
2015 Transition Relief
pp. 418-419
50-99 Employee Relief
 Not considered elimination or material
reduction in coverage if:
▪ ER contributions ≥ 95% of $ or ≥ %
of cost paid on 2/9/14
▪ Benefits changed but still MV
▪ Class of EEs covered not narrowed or
reduced from those covered 2/9/14
2015 Transition Relief
pp. 418-419
50-99 Employee Relief
 Relief applies to all months of a plan that
begins in 2015 (includes those in 2016)
 If qualifies for relief, still an ALE in 2015
 Required to file information returns
 ER certifies qualification on Form 1094-C
▪ Box 22C in Part II
2015 Transition Relief
> 100 Employees Relief
p. 419
 Coverage requirement met if offer to ≥
70% of full-time EEs
 Check Box 22C, Part II, on Form 1094-C
p. 419
Applicable Large Employer (ALE)
 Employer with ≥ 50 FTEs in 2014
 For-profit, nonprofit, or gov’t entity
 Businesses under common control
▪ One employer for ALE determination
▪ Separate for ESRP determination
p. 419
Businesses Under Common Control
Ex. 11.1
Corp Z owns 100% of Y and X
2015 FTEs: Z: 0
Y: 30
X: 40
FTEs combined ≥ 50, each is an ALE
If 70 in 2014 & group met all 3 conditions,
could qualify for 50-99 relief in 2015
p. 420
Businesses Under Common Control
Ex. 11.2
Business as sole prop
2015: 15 FTEs
Owns 80% of ABC P/S
2015: 40 FTEs
Sole prop and ABC P/S = 1 Employer
Sole prop and ABC P/S are ALEs for 2016
If 2014 FTEs of 55, will be ALE for 2015 but
may qualify for 2015 50-99 relief
p. 420
Businesses Under Common Control
If businesses under common control
determined to be an ALE
 Each separate business treated as an ALE
 ESRP determined separately for each
 Each must file reporting forms for 2015
 Qualification for 50-99 relief made by the
group combined, not each separately
p. 420
First Year of Existence
Not in existence any business day of prior year
 Will be ALE in current year if:
▪ Expects to employ average of 50 FTEs and
▪ Does employ average of at least 50 FTEs
 For 2015 can qualify for 50-99 relief if for 2015
▪ Reasonably expects to employ < 100 FTEs
▪ Reasonably expects & does meet tests for
workforce, hours, coverage from first day
p. 420
Full-Time Employees
Full-time = 30 hour/week average
or
130 hours any given month
All employees in for ALE determination




Must include those exempt from coverage
Must include those eligible for other coverage
Seasonal worker exception
Religious order exception – vow of poverty
p. 421
Full-Time Equivalents
Using those working < 30 hours/week
 Total hours per month (up to 120 each)
 Divide total by 120
 Round to nearest one hundredth
p. 421
ALE Determination
 Determine average FTE count of prior year
▪ Total full-time employers and full-time
equivalents for each month
▪ Add together all months totals
▪ Divide yearly total by 12
 For 2015 determination only, may use any
consecutive 6-month period in 2014
 Example 11.2
p. 422
Hours of Service
 Hour worked or not worked for which EE paid
or is entitled to pay
▪ Includes vacation, holiday, illness, layoff, jury
duty, military duty, disability, any paid absence
 Does not include:
▪ Bona fide volunteer for a government or taxexempt entity in federal work-study program
▪ Compensation constituting income from
sources outside the U.S.
pp. 422-423
Hours of Service
 Seasonal Workers
▪ One performing labor or services on a
seasonal basis (farm, holiday retail workers)
▪ Counted in number of FTEs
▪ If average FTEs > 50 for ≤ 120 days in year
& seasonal workers caused excess, no ALE
▪ 4 calendar months = 120 days
▪ 120 days/4 months need not be consecutive
pp. 422-423
Hours of Service
 Adjunct faculty: 2.25 hours/teaching hour + 1
hour for each hour outside classroom
 Paid interns counted same as other employees
 Shared employees
▪ Treated as 1 employer, all hours counted
▪ Treated as separate, allocate hours
 Layover hours – p. 423
 On-call hours – p. 423
pp. 423-424
Coverage
 ALE must offer coverage to full-time employees
▪ Affordable AND
▪ Provides minimum value
 2015: Offer to 70% of full-time
 2016 and later: Offer to 95% of full-time
 Offered for a calendar month if for FULL month
 January 2015: Coverage offer by first day of
first pay period treated as January coverage
p. 424
Full-time Employees - Coverage
 Methods to determine is full-time for coverage
requirement (who must be offered coverage?)
▪ Monthly measurement method
▪ Look-back measurement method
 Look-back method cannot be used in
determining full-time for ALE determination
p. 424
Full-Time Employees – Coverage
Monthly Measurement Method
 Identify full-time based on hours of service per
month 130 hours/month (30/week)
 New Employee:
▪ No ESRP if
(must meet both)
• Coverage by day after 3 full calendar mos.
• Coverage provided has MV
• Applies only once per employment period
• Relief even if employee leaves < 3 months
p. 424
Full-Time Employees – Coverage
Monthly Measurement Method
 Rehired Employee
▪ Treated as continuing employee if period with
no hours of service is
• Less than 13 weeks
• Less than 26 weeks if educational org.
• May treat as new hire if period of no hours is ≥
4 consecutive weeks & such period exceeds
length of immediately preceding employment
p. 424
Full-Time Employees – Coverage
Look-Back Measurement Method
 Full-time status determined for future period
(stability period) based on hours worked in
prior period (measurement period)
 Measurement Period
▪ At least 3 months but not more than 12
▪ Employer chooses start and end
• Must be uniform w/in EE category
pp. 424-425
Full-Time Employees – Coverage
Look-Back Measurement Method
 Administrative Period
▪ Optional period
▪ Time to determine EE’s status and notify EEs of
status and eligibility
▪ No > 90 days (can differ for EE categories)
▪ Between measurement and stability
▪ Overlaps prior stability – no coverage break
p. 425
Full-Time Employees – Coverage
Look-Back Measurement Method
 Stability Period
▪ EE averaging 30 hours/week treated as
full-time in subsequent stability period
• Regardless of hours in stability period
• At least 6 consecutive months long
• No shorter than measurement period
p. 425
Full-Time Employees – Coverage
Look-Back Measurement Method
Example 11.6 - 2015
JAN
FEB
MAR
Measurement Period for May 2015 – Oct 2015 Stability Period
APR
MAY
Administrative Period
(Stability period begins)
JUNE
JULY
AUG
SEPT
Measurement Period for Nov 2015 – Apr 2016 Stability Period
OCT
NOV
Administrative Period
(Stability period ends)
(Stability period begins)
DEC
p. 425
Employee Categories
 Measurement, stability, admin periods may vary
in length, start, end for each employee category
▪ Collectively bargained EEs and noncollectively bargained EEs
▪ Each collectively bargained group under
separate agreement
▪ Salaried and hourly employees
▪ Employees primarily in different states
pp. 425-426
Full-Time Employees – Coverage
Look-Back Measurement Method
 New Employees: Reasonably expected to be
full-time employee
▪ Determine status based on hours/month
worked
▪ Becomes ongoing EE after employed for one
complete standard measurement period
▪ Once an ongoing EE, the ER may apply the
look-back method for future periods
p. 425
Full-Time Employees – Coverage
Look-Back Measurement Method
 New Employees: Variable-hour employee,
seasonal, part-time
▪ Determine status with initial measurement
period of 3-12 months
▪ Initial measurement must begin employee’s
start date up to 1st day of next calendar month
▪ Stability period must = that of ongoing EEs
p. 426
Full-Time Employees – Coverage
Look-Back Measurement Method
 Factors for “reasonably expected”
▪ Replacing a full-time or variable-hour employee
▪ Service hours of those in same or comparable
positions in recent measurement periods
▪ Whether job was advertised or otherwise
communicated as involving certain level of
hours per week
pp. 426-427
Minimum Value
 Minimum Value (MV) is covers at least 60% of
total costs of plan benefits expected (bronze)
 Options for determining
▪ HHS website calculator
▪ Plan designed to meet safe harbors
▪ Actuarial Certification
 HSA/HRA (integrated with ER plan) contributions
by ER count as costs if cannot pay plan premiums
p. 427
Minimum Value – Notice 2014-69
 Minimum value ONLY if meets 60% test
PLUS
Benefits include substantial coverage of inpatient
hospital services & physician services
 New definition applies to 2015 plan years
 Certain plans in process at 11/4/14 excepted
p. 427
Minimum Value – Notice 2014-69
 ALEs with nonhospital/nonphysician plans will not
be subject to ESRP on 2015 plan if:
▪ Binding written commitment to adopt such a
plan prior to 11/4/2014
▪ Enrolled employees prior to 11/4/2014, relied
on HHS MV calculator and plan year begins no
later than 3/1/2015
 EEs may treat all such plans as without MV for
purposes of PTC
p. 427
Affordable Coverage
 ER coverage not affordable if self-only premiums
exceed 9.56% of EE’s 2015 household income
 Employer safe harbors – Employee premium for
lowest cost self-only plan does not exceed
▪ 9.5% Form W-2 wages
▪ 9.5% Employee’s rate of pay
▪ 9.5% Federal poverty line
 Safe harbor used reported on Form 1095-C
p. 427
Liability for ESRP
ALE liable for an ESRP if ≥ 1 full-time employee
gets premium tax credit
AND
Employer failed to offer MEC to 70% of full-time
employees for 2015 (95% for 2016)
OR
Coverage offered not affordable, not of minimum
value, or not offered to employee getting the PTC
p. 431
Offer of Health Coverage
 Offer made if employee has effective opportunity
to enroll or decline once per plan year
 If coverage continued, provide chance to opt out
 First year as an ALE – no ESRP for Jan-Mar if
coverage offer by April 1
▪ Not first year as ALE in 2015 (2016) if met ALE
definition in a prior year 2014 (2015)
pp. 431-432
Dependent Coverage - Transition Relief
 2015 plan year - no ESRP if
▪ Dependent coverage not offered,
▪ Dependent coverage offered not of MV, or
▪ Dependent coverage offered to some but not all
 N/A if dependent coverage offered in 2013 or
2014 plan year and was dropped
 Applies to dependents not offered in 2013/14 if
steps taken in 2014/15 to extend them coverage
p. 432
Notices to Employers
 Section 1411 Certification
▪ Sent to employer by Exchange when an
employee determined eligible for PTC
▪ Employer may appeal – within 90 days
▪ Appeal determination sent to employer and
employee
▪ Appeal determination does not affect employer
ability to challenge a later IRS ESRP proposal
p. 433
ESRP Calculation - § 4980H(a)
2015
Offer not made to 70% of FT EEs and ≥ 1 FT EE
gets PTC (based on Section 1411 certifications)
ESRP = $2,080 x (# full-time employees – 80)
 FT equivalents and employees in a limited
nonassessment period not in # of full-time
 80 reduction is allocated if in related group
 Computed monthly if offer made for some months
49
p. 433
ESRP Calculation - § 4980H(a)





Example 11.12
102 FTEs in 2014 => ALE in 2015
92 full time in 2015
Offer to 50 full time, 50/92 = 54%
2 full-time employees qualify for PTC
 ESRP = $2,080 x (92 – 80) = $24,960
50
pp. 433-434
ESRP Calculation - § 4980H(a)





Example 11.13
102 FTEs in 2014 => ALE in 2015
92 full time in 2015
Offer to all full-time employees beginning 9/2015
2 full-time employees qualify for PTC Jan-Aug
 ESRP = ($2,080 x 9/12) x (92 – 80) = $16,640
51
p. 434
ESRP Calculation - § 4980H(b)
 ALE meets coverage requirement but ≥ 1
employee gets PTC because coverage:
▪ Does not provide minimum value
▪ Is not affordable for an employee
(self-only premiums > 9.56% household income - 2015)
▪ Not offered to employee getting PTC (in 30%)
 Computed monthly
 ESRP = # FT getting PTC x $3,120/12
 Limited to what 4980H(a) ESRP would have been
52
p. 434
ESRP Calculation - § 4980H(b)
 Example 11.14
 Dillon offered coverage to all full-time employees
 Not affordable for 2 employees – purchased
Marketplace coverage/received PTC for 12 mos
 Employer did not qualify for any affordability safe
harbor
 ESRP = $6,240
$3,120 / 12 x 2 PTC employees x 12 months
 $6,240 < $24,960 if coverage % not met
53
p. 434
ESRP – Other Considerations
 ESRP is non tax deductible
 Dollar amounts subject to annual inflation adjustmt
 Full-time employee count for computation of ESRP
▪ Excludes full-time equivalents
▪ Excludes EEs in Limited Nonassessment Period
(Period in which an employer is not assessed an ESRP
regardless of whether an offer made)
54
p. 434
Limited Nonassessment Period
For § 4980H(a) only if coverage is offered by the 1st
day of the 1st month following the end of the period
or
For § 4980H(b) only if coverage offered at the end of
the period provides minimum value
1. First year as ALE – runs January thru March –
applies only to EEs not offered coverage in past
55
pp. 434-435
Limited Nonassessment Period
2. Waiting period / monthly measurement method
▪ Begins 1st full month EE otherwise eligible
▪ Ends 2 full calendar months after 1st full month
3. Waiting period / look-back measurement method
▪ EE reasonably expected to be full-time
▪ Begins on EE’s start date
▪ Ends at end of 3rd full calendar month of
employment
56
p. 435
Limited Nonassessment Period
4. Initial measurement period & admin period under
look-back measurement method
▪ Variable-hour, seasonal, or part- time EE only
57
p. 435
Limited Nonassessment Period
5. Period following EE status change occurring in
initial measurement period in look-back method
▪ Begins on date EE’s status change
▪ Ends no later than end of 3rd full calendar
month following status change
▪ Only if:
• Variable-hour, seasonal, part-time @ start
• In new position/status would have
reasonably been expected to be full-time
58
p. 435
Limited Nonassessment Period
In all cases:
6. First partial calendar month of employment
▪ If 1st day is other than the 1st day of a month
59
p. 437
Health Coverage Reporting
 Form 1095-C and Form 1094-C
▪ Employers with > 50 FTEs
 Form 1095-B and Form 1094-B
▪ Health insurance issuers – individual market
coverage and employer plans (includes SHOP)
▪ Small employer sponsoring self-insured plans
 Form 1095-A
▪ Marketplace coverage
60
p. 437
Form 1095-C
 Due dates to IRS – same as W-2
▪ 30-day extension with Form 8809
 Furnish to employee same date as W-2
▪ Mail or electronic (if consent)
 One per EE who was FT any time during the year
 Limited nonassessment period EE ≠ full time
 One per any EE with self-insured coverage for EE
or any family member whether FT or not
 Used for ESRP and PTC purposes
61
pp. 437-439
Form 1095-C
Part II, Line 14:
 Codes for whether or not coverage was offered
 Month by month entries or “all 12 months” box
 Offers for a month only if coverage for every day
 Terminated EE, coverage for the month if would
have been covered every day if stayed
 Codes in Figure 11.7, page 439
62
pp. 439-440
Form 1095-C
Part II, Line 15:
 Entry only if code 1B, 1C, 1D or 1E in line 14
 Lowest cost monthly premium for self-only –
including cents
 If no employee cost for self-only, enter 0.00
Part II, Line 16
 Codes for eligibility for safe harbors/other relief
 Figure 11.8, page 441
 Entry not required but in the ER’s best interest
63
pp. 440-441
Form 1095-C
Part III
 Employer sponsored self-insured coverage
▪ List any employee and/or family members
▪ List nonemployee and/or family members (1G)
▪ Date of birth entered only if SSN unknown
▪ Check any month with at least 1 day coverage
64
pp. 442-443
Form 1095-C
Example 11.15 – New Employee
 Joyce employed 5/1/2015 through 12/31/2015
 3 month waiting period
 Enrolled in coverage August 1, 2015
 Form 1095-C on page 443
(insert $100 in line 15 for Aug through Dec)
Note: If Joyce had Marketplace coverage with PTC,
she could continue it until the end of July.
65
pp. 443-444
Form 1095-C
Example 11.16 – Terminated Employee
 Bob employed 1/1/2015 through 9/30/2015
 Offered MEC with MV but declined
 Form 1095-C on page 444
Note: Employer’s affordability safe harbor eligibility
does not affect Bob’s possible PTC if 9.56% of his
actual household income is < the self-only premiums
66
pp. 444-445
Simplified Reporting Methods
Qualifying Offer Method
(N/A is self-insured plan)
 Qualifying offer for all 12 months to the FT EE
 Form 1095-C to IRS - Simplified statement to EE
Qualifying Offer Method Transition Relief for 2015
 Qualifying offer for ≥ 1 month to 95% of FT EEs
 Form 1095-C to IRS - Simplified statement to EE
98% Offer Method
 Safe harbor affordable, MV to 98% EE’s & dep. 67
pp. 445-448
Form 1094-C
 Transmittal of Forms 1095-C
 Summarizes Form 1095-C information
 If filing one for each division, one must be
designated as “authoritative transmittal”
 Each member of ALE group files it owns
▪ Identifies other member in Part IV
 Part II, #22 – Eligibility certifications
 Part III – monthly information or “all 12 months”
68
pp. 448-449
Form 1095-C Penalties
 Information return penalties - § 6721, § 6722
▪ Increased penalties after 12/31/2015
▪ 2015 penalty relief if incomplete or incorrect
• Can show good faith effort to comply and
• Form timely filed (IRS) or furnished (EE)
 Can avoid if reasonable cause met under § 6724
69
pp. 449-451
Form 1095-B
 Filed by health insurance issuer
▪ Individual marketplace policies
▪ Employer sponsored insured plans
▪ SHOP plans
 Filed by small employer sponsoring self-insured
 Filed for Government-sponsored plan coverage
 Filed for other coverage as designated by HHS
 Filing/furnishing dates same as 1095-C / W-2
70
pp. 452-456
Failure to Comply w/ Market Reforms
 $100 per day per person excise tax if employer’s
plan fails to meet market reforms
 N/A to excepted benefits if separate policy
 Notice 2013-54
▪ Employer payment plan – Subject to tax
• Reimburses individual policy premiums
▪ HRA – Not subject if integrated with group plan
▪ FSA – Subject if not an excepted benefit
▪ EAP – Not subject if excepted benefit
71
Notice 2015-17
pp. 456-459
Excise Tax Transition Relief
 Employer Payment Plan – no excise tax
▪ If employer not an ALE
▪ Applies January 1, 2014 thru June 30, 2015
▪ NOT: stand-alone HRAs/other reimbursement
arrangements
 Healthcare arrangements for 2% S corp S/H-EEs
▪ No excise tax until the later of the end of 2015 or
when additional guidance issued
72
Notice 2015-17
pp. 456-459
Excise Tax Transition Relief
 Medicare Premium Reimbursement Arrangements
▪ Cannot be integrated with Medicare coverage
▪ May be integrated with another employer plan
▪ If plan for < 2 current EEs, not subject to reform
 TRICARE-Related HRAs
▪ Cannot be integrated with TRICARE
▪ May be integrated with another employer plan
73
Notice 2015-17
pp. 456-459
Excise Tax Transition Relief
 Increase in compensation not tied to purchase of
health coverage is not an employer payment plan
 Reimbursements of insurance premiums cannot
be on an after-tax basis
▪ Rev. Rul. 61-146 holds nontaxable
Note: Only way after 6/30/2015 to help employees
pay premiums is no-strings-attached compensation
74
Excise Tax
pp. 459-461
Nondiscrimination Rules
 PHS § 2716 bars fully insured plans from
favoring the highly paid
 IRS will not enforce penalty until it issues
guidance for plan sponsors
 I.R.C. § 105(h) tests both eligibility and
benefits actually provided
 Shareholder plans are vulnerable
75
p. 461
Expatriate Health Plans
 Granted relief from market reforms
▪ Temporary relief through 12/31/2016
▪ 2014 EHCCA made relief permanent for certain
contracts on or after July 1, 2015
▪ EHCCA extended relief to self-insured plans
 Exempt from PICORI fee, transitional reinsurance
fee, health insurance provider fee
 Subject to reporting requirements
 May be subject to Cadillac Tax in 2018
76
pp. 462-463
SHOP Marketplace






If ≤ 50 FTEs can use SHOP
Bronze, silver, gold, platinum plans
Employer chooses plan or plans
Employer determines contribution
Must offer to all FT employees (30 hours/week)
70% FT EEs enrollment needed to apply outside
11/15-12/15 period
NOTE: 2015 PACE Act allows states to determine if SHOP
eligibility to be up to 100 FTEs in 2016
77
Questions?
78