Two other solutions come to mind:
1. Ensure that one of the principals is a Catholic, as I believe that Catholics will succeed in defeating this mandate in the courts
2. Create subsidiaries that employ fewer than 50, all of whom are hired to fill roles as a third party vendor. This is different than an ‘independent contractor’ situation, in that workers are employees of the cusidiary corporation.
This would be a relationship similar to hiring a janitorial service to provide in-house cleaning services.
The scope of duties would have to be narrow, but it could be a practical solution for some needs for some companies.
oooppss.....cusidiary? listening to Rudy Giuliani right now..no multi-tasking for me! I meant ‘subsidiary’ !