My guess is that I have over 40 hours put into developing a plan of action for distributing the notices to my clients. Even yesterday Hank and I were exchanging emails on this topic. On top of my time, many hours have been put in across our professional organization in determining and defining things like minimum value standard and affordability.
According to the original draft, the notice was supposed to be sent out by March 1, 2013, but then there was a delay. So, now the notice must be distributed no later than October 1, 2013. The DOL guidelines state that non compliance will result in a $100 per employee per day fine. So you can see why we have such a sense of urgency behind this matter.
This came September 11, 2013 at 4:55PM. In a frequently asked questions release the DOL determined that while the notice should be distributed there are no fines or penalties for failing to provide the notice. So in the course of a couple of months the government has gone from "we will fine you" to "meh, no big deal".
Just another one of our great government efficiencies...