It’s common for employers to think about their health plans only during open enrollment, when you’re considering plan design changes and offering benefits to your employees. This year, with the Affordable Care Act in effect, you’ll have to be sure to address additional items throughout the year – more than just new enrollments, election changes and claims issues.
Now that open enrollment is over, you need to be thinking about the new reporting requirements for 2016. If you had 50 or more full-time plus full-time equivalent employees during your 6-month testing period in 2014, you will need to issue 1095-C reports to all full-time employees. If your plan is self-funded, you will have to also issue 1095-C reports to any employee (whether or not full-time) who was covered under your health plan for at least one month during the 2015 calendar year.
Although your payroll vendor may be promising to provide you with the information you need to prepare these reports, there are a few questions that you should ask:
- How will they collect information on employees who are full-time but not covered by the health plan?
- Are they able to track time during a family or medical leave in compliance with the rules?
- Will they provide the monthly codes or will they ask you to do that?
Tracking Full-Time Employees
In addition to preparing for reporting, you will still need to monitor and track employees to determine whether they are full-time based on changes in hours or job classifications. You are permitted to use different measurement periods for salaried and hourly employees, for employees in different states and for union/non-union employees. They can also use a monthly measurement method for certain employees based on a reasonable classification. A monthly method will help if you want to make employees ineligible for coverage if they change positions or reduce their hours. Looking at all groups of employees and understanding how the rules affect eligibility will help you manage your workforce.
As these changes are being made to eligibility rules and job classifications, you will also need to work on ensuring that your documentation is up-to-date and accurately reflects the requirements for eligibility. This means you should be reviewing your plan documents.
So, while open enrollment may be a thing of the past, your work may not be done. You should remain focused on your healthcare plan throughout the year.
All of these new requirements can be overwhelming. Bell Associates and our team of ACA experts can help you make sure you’re doing everything necessary to comply with the new regulations. Contact Bell Associates at 203-707-1300 or email email@example.com. You can also visit us at www.bellassoc.com.
This article refers to regulations issued through December 31, 2014. It is intended to be a summary of important issues and should not be considered legal or tax advice.
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