Happy New Year - Now Get to It!
So it’s 2015 – Happy New Year! I hope you had a great holiday season! My family and I certainly did, though my seven-year-old was ready to go back to school pretty quickly. Her friends were all out of town so she came up with a new saying during the long break – “Say Boo to Boring!” – and I agree! If nothing else, make 2015 an exciting year!
What does that have to do with compliance? Well, since its 2015, the Affordable Care Act’s Employer Mandate is, at long last, in place. It’s been a long road getting here – reams and reams of regulatory “clarifications” (and clarifications to the clarifications if you get my meaning). Plus endless hours of talking heads…well, talking (as that’s what they do after all), instructional classes, internal and external discussions (some probably heated!) and more. 2014 was a long hard run-up – and here we are at the finish line. Or are we?
It feels like we should be done – after all, the plans are in place, enrollments are over with, and we’re off and running, right? Well yes, but don’t think that means we can move on to other things. There are still plenty of ACA and benefits-related tasks to accomplish, both from the employers’ perspective, and the government’s.
Practically speaking, the Employer Mandate creates a new set of day-to-day administrative responsibilities for employers. Whether that’s simply an increase in work due to having more people covered under your plan, to changing procedures to properly capture employee data for the upcoming ACA reporting, the practical impact of the ACA is just now beginning to take shape.
We also have more ACA rules coming. Those of you who aren’t subject to the Employer Mandate this year because you’re in the 50 to 99 employee demographic, it’s your turn now. That long run-up has just begun for you. We’re also expecting additional guidance in some areas that haven’t yet been addressed – insured plan non-discrimination rules, auto-enrollment rules and probably more talk on the upcoming Cadillac Tax.
Finally, toss a new united Congress into the mix, and you open up another can of worms. As I write this article, the new House of Representatives has passed a bill to change the definition of a full-time employee to 40 hours per week. This has happened in the past, but those bills never got anywhere in the Senate because the Democrats wouldn’t vote for that measure. Now, already anticipating that the new Republican Senate will approve the measure, the President has announced he’ll veto it. For the first time however, there’s the possibility that the Senate will be able to get enough votes to override a Presidential veto, so stay tuned!
2015 is going to be an interesting year in the compliance world. It’ll require employers to remain nimble and focused. As usual, the compliance team at Assurance will stay on top of it and make sure our clients remain informed, educated and ready to deal with whatever is coming our way. One thing’s for sure – we won’t have to say “boo to boring!”
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