What’s Your Compliance Score?

Most employers are already using a payroll/HRIS system to pay employees and track data. Many don’t realize they may already have the tools they need to track the ACA requirements. Below is a checklist for employers to use when assessing their providers capabilities.

Now that the Affordable Care Act is in place, it is important that employers automate as much as possible to stay compliant with the law.  You can evaluate how your technology can track, report and automate particular portions of the ACA.

The average ERISA fine (ACA falls under ERISA) is $1,000 per day – per offense.  That means that each item found non-compliant, a penalty of $1,000 per day can be assessed.   However, when it comes to offenses pertaining to employees, the penalty could be as high as $1,000 per member per day.  Penalties for non-compliance can add up quickly and be very costly.    

Dependent Coverage (2010) – Plans must provide coverage for eligible dependents to age 26, including those who are not enrolled in school, not dependents on their parents’ tax returns, and those who are married.
Can dependent children be covered until age 26? Yes  or  No
Is this automated? Yes  or  No
Can it be tracked and reported on? Yes  or  No
Additional Notes: 
In Compliance Not in Compliance

 

SBC’s (2012) – Employers must distribute the Summary of Benefits and Coverage document.
Do administrators have the ability to load the SBC’s online? Yes  or  No
Do you support hard copy or electronic distribution of SBC’s? Yes  or  No
Do employees have the ability to acknowledge receipt of SBCs? Yes  or  No
Is this data reportable with dates of acknowledgements? Yes  or  No
Additional Notes:
In Compliance Not in Compliance

 

Employee Notice of Exchange (2013) – Employers must distribute a notice to employees of the availability of the public exchange.
Do administrators have the ability to load the Notice of Exchange online? Yes  or  No
Can you create the Notice of Exchange including employer specific data? Yes  or  No
Can you support hard copy and electronic distribution of the Notice? Yes  or  No
Do employees have the ability to acknowledge receipt of Notice of Exchange? Yes  or  No
Is this data reportable with dates of acknowledgements? Yes  or  No
Additional Notes:
In Compliance Not in Compliance

 

Form W2 Reporting (2013) – The W-2 needs to report both the employer and employee cost in one field.
Can you calculate employer and employee total premium cost of applicable plans and report to payroll to be included on W2? Yes  or  No
Is this automated? Yes  or  No
Can you report costs on periodic payroll files as well as on a year-end report? Yes  or  No
Is this automated? Yes  or  No
Describe how you support W2 reporting for mid-year terminations. Use space below
Additional Notes: 
In Compliance Not in Compliance

 

Patient-Centered Outcomes Research Institute (PCORI) Fees (2013) – Employers who are self-insured need to report covered lives on the medical plan(s).
Do administrators have the ability to run a specific PCORI report? Yes  or  No
Do administrators have the ability to run a point in time report to track covered lives on all medical plan(s)? Yes  or  No
Additional Notes: 
In Compliance Not in Compliance

 

Wellness Incentives/Programs (2014) – Employers can offer wellness incentives to employees for participation in wellness programs.  These incentives can offset premiums for healthcare.
Describe your ability to apply credits and adjust employee contributions based on completion of wellness programs, as provided via files/data imports, etc. Use space below
Does this involve administrator input? Yes  or  No
Additional Notes:
In Compliance Not in Compliance

 

Fulltime and Part-time Status (2015 for employers with 100+ employees, 2016 for employers with 50-99 employees) – Employer mandate to offer affordable coverage to all FT employees (over 30 hours per week).
Do administrators have the ability to run a specific report to track variable hours for this ACA requirement? Yes  or  No
Do administrators have the ability to track hours worked by employees? Yes  or  No
Do administrators have the ability to pull reports showing hours worked for the previous 12 months? Yes  or  No
Do administrators have the ability to view employees approaching 30 hours? Yes  or  No
Can this be automated to flag administrator or manager? Yes  or  No
Do administrators have the ability to run a specific W2 Safe Harbor Test?  (9.5% of employee’s wages as reported in Box 1 of the W2) Yes  or  No
Additional Notes:
In Compliance Not in Compliance

 

6055 & 6056 Reporting (Extended to 2015) – The pay or play rules require employers to report certain employee coverage information to the IRS.  These reporting requirements are for employers with 100+ employees.  Employers with self-insured plans are responsible for both reports, while employers with fully-insured plans are only responsible for the 6056 report.
Do you have the ability to produce the 6055 and 6056 tax returns today? Yes  or  No
If not, is that in development? Yes  or  No
Additional Notes: 
In Compliance Not in Compliance

 

Automatic Enrollment Rule (Pending guidance) – This ruling requires employees be auto enrolled in the base medical plan.
Do you have the ability to auto enroll employees into medical coverage today? Yes  or  No
If not, is that in development? Yes  or  No
If so, is it an automated process? Yes  or  No
Additional Notes: 
In Compliance Not in Compliance

Please contact with questions:

Benefit Technology Resources

877-299-8155

www.bentechre.com