More PPACA group health provisions are supposed to begin taking effect in 2015. The current schedule calls for a transitional version of the PPACA “play or pay” employer coverage mandate to apply to employers with 100 or more full-time employers, and to some employers with 50 to 99 employees. Employers will have to keep track of which employees were offered health coverage in any given month, and large employers will have to put the employee count data they collected in 2014 into Internal Revenue Code Section (IRC) 4980H “employer shared responsibility” reports.
Meanwhile, some of your employee clients may still be scrambling to create, and understand, their PPACA compliance checklists. What should those clients be doing to make sure they’re ready for 2015?
1. Review existing measurement systems.
Are your clients equipped to determine employee status, while considering measurement and stability periods, to provide coverage as soon as an employee becomes eligible?
2. Determine excise tax penalty risk by entity.
Your clients should identify potential full-time employees not offered coverage.
3. Assess reporting systems.
Are your clients’ reporting systems capable of gathering and aggregating the required information for IRS reporting – by employee, on a by-month and by-entity basis? Reports are due to the IRS in 2016, but data collections begins January 1, 2015. How do companies manage data residing in multiple locations? This is especially difficult for employers with a contingent or variable workforce.
4. Prepare for Marketplace/Exchange notices.
In November, open enrollment begins and even businesses offering affordable care to employees are likely to receive Marketplace notices. Notices must be analyzed for accuracy and any erroneously issued notices must be appealed within the designated timeframe – which can vary by state (typically 90 days).
5. Develop a plan for IRS assessments.
Will your clients be able to provide supporting analysis and documentation to defend against erroneous assessments?