In late January, a district court in Florida ruled that the Patient Protection and Affordable Care Act (PPACA) is unconstitutional. While the constitutionality of PPACA is an issue that likely will have to be resolved by the Supreme Court (perhaps in 2012), the ruling in Florida adds further uncertainty as to whether PPACA can stand up to constitutional scrutiny. Four district courts have ruled in cases on PPACA to date. Two have upheld the individual mandate and two have ruled that it is unconstitutional. In the meantime, until these legal challenges are fully resolved, employers, insurers, and providers are left with little choice but to continue their efforts to comply with PPACA’s mandates and deadlines. (State of Florida, et al. v. United States Department of Health and Human Services, et al., N. D. Fla. 2011)