In Room 408B of the Los Angeles Convention Center, in-house lawyer Ron Peppe had a secret to share about Affordable Care Act compliance: Utah.

Under the law’s “employer mandate,” businesses must make insurance that covers “essential health benefits” available to their full-time employees at a reasonable price by January 2015 or risk fines. But states may specify what they consider vital. And employers can pick any state they wish to follow, even if they don’t do business there.