Garrett Fenton commented on what companies should be doing now to prepare for implementation of the Affordable Care Act (ACA). Fenton said that even with a year's implementation delay for some requirements, companies should work with their vendors now to prepare their reporting to the IRS on health plans offered to employees. He noted that the information requested is quite detailed and is important to collect accurately to demonstrate weather "pay-or-play" penalties will apply. Fenton said that the bar to begin review is low. In some cases, "as long as one employee goes into one of the exchange[s] and gets a tax credit, that flips a switch to trigger this pay-or-play penalty...if necessary," he said. Fenton also reviewed how companies calculate their full-time equivalent employees under the pay-or-play rules, and discussed when employers need to begin paying transitional reinsurance program fees.