Late last month, the federal agencies responsible for the administration and enforcement of the Affordable Care Act (ACA) issued guidance in the form of Notices 2012-58 (issued by the IRS) and 2012-59 (issued by the Department of Labor, the Department of Health and Human Services, and the Treasury ). Notice 2012-58 provides employers with safe harbor methods for determining whether an employee is a full-time employee for purposes of the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code (i.e., the so-called “play-or-pay” mandate). Notice 2012-59 provides guidance on the prohibition against waiting periods in excess of 90 days. These requirements become effective January 1, 2014.