It's Go Time for ACA Compliance
I sat down to write this post with the intent of summing up the fact that 2014 is largely over with, 2015 is around the corner, and that means the Employer Mandate is imminent. Then by chance I checked the date – October 12. How in [insert favorite expletive] did it get to be mid-October already?! To say 2014 is flying by is an understatement! No wonder I didn’t remember the date…
From a compliance perspective, I could say all sorts of things – make sure you’ve got your Ongoing Measurement and Stability Periods set, and have your minimum value plan selected, including the calculation of what you can charge employees to meet the affordability requirements. Have hourly employees? Make sure you’ve tested your time keeping systems to ensure your ability to determine how many hours each employee works per calendar month (and that means splitting pay periods up in some cases.) In other words, make sure you’re up to speed with the ACA mandate and ready to rock on January 1.
Or, I could look at other issues – end of year non-discrimination testing for those of you with Cafeteria Plans or self-funded health plans (or both!) There are the Medicare Part D notices…along with the rest of the DOL’s required annual notices. Changing your health plan this year? Switching from Carrier A to Carrier B? If so, it’s time to update the plan document to reflect those changes. Still maintaining a grandfathered health plan? Don’t forget those grandfather notices!
Lots of balls to juggle, aren’t there? The thing is – I could say any of those things and be giving you good, solid compliance advice. But, the reality is the best thing I could advise you to do is all of those things – they’re all necessary – at least all the ones that apply to you. In fact, that’s another thing for the list – evaluating all the various employer requirements to make sure you’re only dealing with the ones you need to deal with.
It’s definitely “go time!” 2015 starts a whole new era of employer health plan compliance that’s unprecedented – at least, in the 16-plus years I’ve been working in the compliance field. We’ll talk more about that in the near future. For now – if you don’t have your game face on, what are you waiting for?
As the Assurance ACA Coach, I've put together a list of resources here that will help you not just get in the game, but win it!
Step 1: Download my ACA Final Preparations White Paper
Step 2: Download my ACA Playbook
Step 3: Check out these free Assurance University Webinar Replays:
- ACA Series: Your Compliance Strategy
- ACA Series: Variable Hour Employees & Safe Harbors
- ACA Series: Reporting Requirements
- ACA Series: Understanding Transitional Guidance
- Final ACA Rules
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