For many “large” employers, determining whether to “pay or play” may not be an easy process. The ACA’s employer shared responsibility provision goes into effect in 2014, making advance preparation even more important if you have part-time, seasonal or “variable hour” employees. Since you are only required to either potentially pay (a penalty for) or play (offer coverage to) those individuals who are considered your full-time employees, your ability to substantiate whether an employee is or is not “full-time” will be critical to successfully navigating the “pay or play” provisions of the ACA.