Are you sure that's the deadline date?
IIRC, there is a 90-day time limit after the bill was signed into law. That would put the deadline for certification sometime in early December (the 8th I believe) rather than the end of the year.
no. I have read in several places that the law takes effect on January 1. That doesn't mean that what I read was true. If it is wrong, please let me know.