ACA PAY OR PLAY – WHAT JULY 1, 2014 MEANS TO YOU
If you’ve been waiting for the IRS to make any additional changes or release more information before putting a health care reform strategy into place, you may want to rethink your approach.
The passing of July 1, 2014 on the calendar heralds your measurement period for compliance. The final regulations that the IRS released in February mandated that your measurement period must begin no later than July 1, 2014. Additionally, this measurement period must be at least six months long and can end no earlier than 90- days before the first day of the first plan year beginning on or after January 1, 2015. Unless you are using the month-by-month analysis of your employees’ statuses, you’ll be using the look-back measurement period safe harbor to determine full-time status. Regardless of what your plan year is and whether or not you have been planning how to gather data – you are currently in your mandated measurement period now.
Do you have the tools in place to make sure your measurement period is reflective of your situation? Some of the data under consideration:
- Accurate records of who is employed (hire and term dates)
- Accurate and easily aggregated timesheet information (service hours worked per month, employment schedules, notice of when employees may be approaching a full-time upgrade or a part-time downgrade)
- Documentation of which employees (and their eligible dependents) were offered coverage, which employees enrolled, which employees declined
You will only have a short amount of time in your administration period (maximum permissible period is 90 days) to determine what this information means to your organization and what benefits enrollment strategy works for you in your stability period.
In our busy business world where there are never enough hours in a day, the remaining portion of 2014 will have a defining impact on how you make out with compliance in 2015.
