Your Most Important Checklist for 2014
Guidance on the Affordable Care Act (ACA) is being released on a fast and furious basis from the Department of Labor, IRS, Centers for Medicare & Medicaid Services, and Health & Human Services. In the midst of this flurry of regulatory activity, the basic planning for compliance can sometimes get overlooked due to justifiable cost concerns.
Regardless of the size of your organization, there are steps in your benefits administration that you should be reviewing now to make your life a little easier in preparation for January 1, 2014 compliance. Here are some of those steps:
- If you are not sure if you are considered a “large” employer, preliminary calculations should be completed now in order to make sure you have the data needed to calculate later this year.
- Review the current employee contribution strategy and determine if your contribution to single coverage of your base plan exceeds 9.5% of W-2 income for any of your employees.
- Review eligibility policies and prepare to adjust effective January 1st, if necessary.
- Be prepared to distribute the required employee notice regarding the opening of the exchanges late this summer or early fall. This would be a good time to do an employee-education session to inform employees of your organization’s plans for 2014. For example, you would want to tell them whether you are considered a large or small employer, whether your coverage will meet the affordability and minimal coverage standards, who is considered a full-time employee for eligibility, etc.
- Determine initial and standard measurement periods for variable-hour employees.
- If you have part-time employees that work variable hours, you may want to educate supervisors/managers on controlling hours worked each week so you don’t have to worry about someone creeping into “30-hour” full-time status.
- Review “seasonal” employees to make sure they will fit the definition.
- Have a contingency plan in place if currently utilizing a temporary staffing agency, in case future guidance has an adverse impact on this type of employment.
- Start the conversation with your payroll provider regarding additional required timekeeping records to comply with new IRS reporting requirements around hours worked, hours paid where no work was performed (PTO, vacation, holidays, sick, disability payments, etc) and unpaid FMLA hours.
- Employers, large and small, may experience inquiries and audits by government entities around eligibility, affordability, coverage, etc. Employers should create a new employee census that includes the following:
- Date of Birth
- Date of Hire
- Wage Information to include type of wages and amount
- Employee Type – Full-Time, Part-Time, Seasonal, Temporary, Commissioned, etc.
- Whether or not they are eligible for employer coverage
- Enrollment Status [plan and current enrollment – waiver, employee, employee/spouse, parent/child(ren), family, etc.]
- Employee and employer contribution amounts to premium
- Signed waiver forms for employees who decline employer coverage should be mandatory.
- Review current plan costs to determine if the Cadillac Tax may be an issue for your organization in 2018. Depending on your findings, it may be wise to make incremental plan changes starting in 2014 so there are no surprises in 2018. (While this is provision is certainly subject to regulatory tweaking, organizations need to start assessing risk now in case steps need to be taken to mitigate impact.)
All of these action items can be a daunting task. However, if you don’t have the resources to complete the analysis and take the necessary steps to prepare for 2014, help is available. Call MEA for more information on how we can assist by completing a detailed analysis of your organization’s risk areas and providing recommendations for the path forward into 2014.