Mercer, a professional services provider specializing in talent, health, retirement and investments, says employers have 10 tasks they should perform over the next year to comply with the Affordable Care Act. They are:
1. Pay or play. Decide whether to "play" and provide employer-sponsored, ACA-compliant coverage to full-time employees, or "pay" employer shared-responsibility penalties. Those penalties start at $2,000 per employee for businesses with at least 50 workers who put in 30 or more hours a week.
2. If playing, analyze the affordability and minimum value of coverage and determine whether, when and how to start counting hours. If paying, establish how full-time employees will be identified for shared-responsibility reporting and penalty assessment. Employers must start reporting information to the IRS in 2015 about health coverage offered on or after Jan. 1, 2014.
3. Understand how the public exchanges will affect your workforce and plan how to best interact with the health insurance marketplace. The public exchanges open Oct. 1. Part-time employees and retirees eligible for employer-sponsored coverage may have opportunities to obtain coverage through the exchanges. Medicaid eligibility expansion (which isn't occurring in Pennsylvania) may also impact coverage.
4. Review plan terms for 2014 compliance. Consider 2014 mandates and current plans that may no longer be permitted and implement required plan changes. The ACA eliminates annual dollar limits on essential health benefits, limitations on pre-existing conditions and waiting periods longer than 90 days. Plans that go into effect next year must comply.
5. Consider increasing wellness program incentives. The ACA allows for increased contributions to wellness programs.
6. Amend plan documents to reflect changes to eligibility, plan design and wellness incentives. Terminate arrangements that are no longer permitted.
7. Prepare and distribute required employee communications, exchange notices, summary plan descriptions and summaries of material modification.
8. Budget for future comparative effectiveness research fees, which will be $2 per covered person next year and indexed to national health expenditures until the program ends in 2019.
9. Plan for new federal reporting. Employers already are reporting the cost of coverage they provide on employee W-2 forms. There will be additional information required after Jan. 1, 2014.
10. Revise Health Insurance Portability and Accountability Act (HIPAA) privacy and security policies and procedures before the Sept. 23, 2013, deadline.
Source: Mercer, www.mercer.com
