The clock is officially ticking on the new healthcare legislation passed in March. Beginning last week, companies’ annual healthcare plans must now reflect the new provisions set out in the Patient Protection and Affordable Care Act (PPACA).

Since the vast majority of companies use the calendar year for health benefits, the true beginning for most will be Jan. 1. The trickier issues for hotel owners and operators won’t arrive until 2014, but Rick Wald, a director with Deloitte, says labor-intensive businesses like hotels need to start preparing for those challenges now.

“2011 is a wakeup call and you’ll have to do some things that don’t cost a lot,” Wald says. “But between now and the first quarter of 2011 you should do scenario planning: ‘What does the future look like, what can we absorb, what do we need to mitigate?’ And then plan mitigation strategies.”

By law, companies with 50 or more employers are now required to offer health benefits, but they won’t be penalized for not doing so until 2014 when the state-based exchanges for health insurance have been created. If companies do offer benefits, they must now comply with the initial provisions of the law, including things like eliminating the exclusion for pre-existing conditions for children under 19, extending benefits to dependent children up to age 26 and the elimination of lifetime dollar limits on essential health benefits.

In 2014, when companies with more than 50 employees are penalized for not offering insurance, the law also changes dramatically for companies like hotels that rely on part-time workers. Employees who work 30 or more hours on average over the course of a month must be offered benefits. Wald offers this example of how this could impact an employer:

“If Rick is regularly scheduled to work 26 hours and something happens in his personal life—a child needs major surgery; a situation where the community would normally come together to rally behind and help raise money for the procedure. In the new world, Rick doesn’t need that help. On Tuesday, Eric calls Rick and says why don’t you take my shift and on Thursday Jane says the same thing. In the month of September, Rick gets 120 hours and needs to be offered benefits. Those will be taken away in October when he’s not working 120 hours, but now he has a right to COBRA. So he doesn’t need half a million for the surgery, but $5,000 for COBRA costs and the claim costs will reside with the employer.”

In 2014, companies with 50 or more full-time employees will be able to choose not to offer health benefits and pay a $2,000 annual fine per employee. Sounds costly, but Wald says it is actually an intriguing option because “you can’t provide benefits for that.”

He says companies could be paying around $5,000 per employee for benefits, so choosing to pay the fine would be cheaper, but there are other implications that need to be considered like employee retention and attraction and public image.

Wald says companies have three scenarios to weigh. The first is to consider the cost increases to offer benefits that comply with the law. The second, the other extreme, is to not offer benefits, pay the fine and let employees purchase health insurance from the state exchanges offering the same type of coverage.

“Today companies provide benefits to attract and retain employees and it’s also more tax efficient for companies and employees to get benefits that way,” Wald says. “If individuals buy insurance now it’s dramatically more expensive and they’re using after-tax dollars, but in 2014 these exchanges will be set up with plans that look like ones offered by employers and offering the same doctors and benefits.”

The third scenario an employer should consider is something between the other two options. “’What can we still do with the plan to be in compliance and spend less today to keep our costs in line,” he says is the question they should ask. “The law says you can have a minimally compliant plan.”

But he says that option is an administrative nightmare and the plan offered won’t be as attractive as what other employers and the exchanges have available. “Either do it or you don’t,” he says. “Getting in the middle isn’t going to work.”

The new law doesn’t affect employers with less than 50 employers who do not offer benefits. In fact, Wald says it will actually be beneficial because their employees will be able to purchase comparable health insurance from state-based exchanges.

Deloitte estimates labor costs currently comprise 45 percent of operating costs and 33 percent of revenues for average hoteliers. Healthcare costs have been rising on average 9.8 percent a year for employers and Deloitte projects that to increase another three to five percent over the next few years because of the new legislation, amplifying the impact of the new law during a time when hotels are fighting to regain revenues lost during the economic downfall of the past two years.

“The most effective thing an employer can do now is educate themselves about their organization and what and how this law affects them,” Wald says. “There are various alternatives that make sense. Start the discussion now internally and prepare an action plan.”

Click here to download Deloitte’s complete report on the implications of healthcare reform for the hospitality industry.