The funny thing about the Affordable Care Act (ACA) is that manypeople who support it will admit — if pressed — that it is a verypoorly drafted piece of legislation.

The overall purpose of the ACA, of course, is to provide ageneral structure for universal health coverage, but Congress leftmost of the details to three federal agencies (the Internal Revenue Service, theDepartment of Labor, and the Department of Health and HumanServices) to sort out on their own. The results have been mixed, tosay the least, though in fairness, the agencies have done the bestthey could with what they were given.

As if that weren’t enough, last year’s King v. Burwell casedemonstrated that the ACA is so badly written that the members ofthe United States Supreme Court — nine of the most intelligent,experienced, learned lawyers in the nation — couldn’t even come toan agreement as to what it actually says and does.

And yet, you may have clients who expect you to know everythingabout how the ACA could possibly affect them under anycircumstance, whether real, hypothetical, or completelyimplausible. After all, you’re the expert, right?

Er, right. But how can you be expected to do what Congress,three federal agencies, and the Supreme Court evidently cannot?

The hard fact is: You can’t.

The good news is that, as we’ve seen, you are not alone. The badnews is that it’s your job to guide your clients. The even worsenews is that — if you’re not careful — you could end up in some hotwater yourself. Losing a client or two might not be the worst ofit, either; you could lose your license.

During my session, “Wise Counsel: Say This, Not That WhenAdvising Clients on PPACA Compliance,” I will walk brokers throughthe minefield that is the ACA. Unlike other ACA seminars, however,which usually focus on the ACA rules themselves (which employersmust comply, what must those employers do, etc.), my seminar willeducate advisors about how to explain and apply those rules totheir clients.

By this point, benefits advisors have at least a broadunderstanding of the ACA and its requirements. That’s a jobrequirement at this stage of the game. But there is still a lot ofconfusion out there with regard to who is responsible for doingwhat things, especially with regard to ultimate determinations oncomplying with the ‘play-or-pay’ rules. There are things thatadvisors can help decide, but there are other things that arebetter left to an employer’s human resources departments, itslawyers, or others.

Just knowing the ACA rules is not enough.

For better or worse, the ACA places a great deal ofresponsibility on employers, which can put benefits advisors — especiallythose who are very actively engaged in their employer relationships— in an awkward position.

They want to help as much as they can, but the ACA has made thisa two-way street. Employers must carry a larger share of theburden, by virtue of the fact that, often, they’re the only oneswith access to the information needed to make determinations aboutemployees.

“Wise Counsel” will help advisors sort out the ACA-relateddeterminations they can make for employers from thosebetter left to their clients or other advisors. My seminar willalso provide useful talking points and other ideas for advisors tohelp ease the transition from the comparatively rules-free pre-ACAworld, in which advisors could practically act as an employer’sproxy for most purposes, to the current world under the ACA where amore arm’s-length relationship is required.

Some people predicted that the ACA would kill the healthbenefits advisor industry. Obviously, and happily, that hasn’thappened. The industry is alive and well and in many ways it’sstronger than ever.

But it has changed the role of broker-advisorsvis-à-vis their employer-clients. That’s not necessarily a problem;in fact, it’s a huge opportunity. But there are new boundaries inplace, and benefits advisors need to be cognizant of them.