Furthermore, the employer mandate is nearly impossible to enforce without robust enforcement of employer reporting. The IRS has broad discretion in enforcing reporting deadlines, and a new commissioner of the agency could largely kill the mandate by waiving reporting deadlines.

Nevertheless, adds Scott Behrens, a benefit attorney speaking with SHRM, “Prudent employers will want to continue to comply with the ACA, including the play-or-pay mandate and reporting requirements … until formal guidance relieves them of those compliance obligations.”

Health policy commentators say that Trump's action was relatively predictable. In contrast to the president's repeated flaunting of long-established expectations of political behavior, he so far appears to be playing within the rules that govern health policy.

Tim Jost, a law professor at Washington and Lee University who studies health policy, suggests in an interview with Vox that he is relieved by Trump's action.

“I was worried [Trump] would do something unpredictable, but this is what I expected,” he says. “I think he's been advised that he can't repeal the Affordable Care Act through executive action, and now we see where this goes.”