Credit unions on the cusp of 50 full-time or full-timeequivalent employees wondering if they must comply with Obamacare in 2014 need to decide now if they will utilize alook-back period option, said an expert from a top industryauditor.

Whether or not a business exceeds the 50 FTE Obamacare thresholdwill be assessed on a monthly basis, said Anita Baker, managingpartner of employee benefit plans at the Minneapolis-based firmCliftonLarsonAllen, which has 350 credit unionclients.

Non-exempt employees who work varied hours could cause anightmare for human resources departments tasked with calculatingFTEs each month, she said.

To provide a safe harbor that allows companies to lock inObamacare compliance status, Baker said the program allowsemployers to apply a look-back method, which involves documentingFTE counts over a period of six to 12 months during 2013.

“Employers really need to determine now if they want to use alook back for 2013,” she said. “If you wait, the process will be alot harder.”

Credit unions that wish to take advantage of the look-backprovision aren't required to notify the federal insurance exchangeor regulators, but Baker said auditors and regulators will check toensure employers document the methodology used to determine FTEnumbers.

“It's just like any other law, you'll have to document you'veused a specific measurement period and if employees took yourcoverage or declined. It's just like any other process,” shesaid.

Although penalties for compliance exceptions are steep – $2,000to $3,000 per employee depending upon the violation – Baker saidthey may not be as expensive as the cost to provide requiredinsurance for employees, especially those who elect for familycoverage.

“Employers are generally paying more than $3,000 per employeefor health coverage, so they may want to look at if it makes moresense to pay the penalty,” she said.

Not-for-profit credit unions should also consider the fact thatbecause they don't pay federal income taxes, they won't benefitfrom the ability to deduct premiums from their federal taxes, Bakersaid.

Additionally, she said, employers should consider the impact onhigher earners should they decide to drop coverage altogether,because only low-wage earners will be eligible for subsidies at thegovernment exchange.

“If they go from an employer's plan where they only pay 20% ofthe premium to paying 100% of the premium, in effect that's asignificant pay cut,” she said.

A recent CUNA Mutual Group survey revealed that only 31% of credit unions are ready tocomply with the Patient Protection and Affordable Care Act.