Employer Mandate and Multiemployer Plan

[Guest Ignatius J. Reilly]

If an employer contributes to a multiemployer welfare fund on behalf of employees, will the employer avoid the PPACA penalties under the employer mandate provisions? Does a multiemployer welfare plan to which an employer contributes constitute an "eligible employer sponsored plan"? I have been unable to find any guidance with respect to interaction between the employer mandate and multiemployer welfare plans, and am concerned that an employer who contributes to such a plan by labor agreement might also find itself liable for the PPACA employer mandate penalties.

Thank you in advance for any insight.