In March of 2010, President Barack Obama signed into law the Patient Protection and Affordable Care Act (commonly referred to as the health care reform law and hereinafter as the “Affordable Care Act” or “PPACA”). Despite its stated dual intent to increase health insurance access and reduce health care costs for Americans, PPACA has evoked intense protests, threats of repeal, and prolonged litigation. Indeed, the United States Courts of Appeals for the Third, Fourth, Fifth, Sixth, Eighth, Ninth, Eleventh, and D.C. Circuits, as well as several federal district courts, considered the constitutionality of PPACA. As the circuits split, the U.S. Supreme Court weighed in this past summer with a controversial 5-4 decision, upholding the constitutionality of PPACA’s “individual mandate,” which is scheduled to take effect on January 1, 2014.