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The Affordable Care Act (ACA) requires covered employers to provide the IRS with month-by-month accountings of all employees – eligible and ineligible, enrolled and not enrolled. For those enrolled, the level of benefits by family status must also be reported. This same information must be shared with each employee. The IRS will compare these rosters to enrollment in the State Exchanges. By 2015, employers not able to do this face penalties and other liabilities. Compliance requires employers to combine facts from payroll files with facts from plan enrollment rosters. This sounds simple but is not. Health Decisions has been combining payroll and enrollment rosters for 15+ years. We have yet to find any that match easily or without effort. This webinar explores the problems employers can expect and what they must do to meet their biggest challenge of ACA compliance. We also explain how, if done correctly, meeting these requirements can lead to savings that can make the effort worthwhile. To view the entire webinar, please go to: https://www4.gotomeeting.com/register/583972327 For more information, please visit: http://www.healthdecisions.com
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Presenter:
Si Nahra, Ph.D., PresidentFebruary 20, 2014
Affordable Care Act (ACA) 2014 Compliance Plan Webinar SeriesSession #2
ACA’s Biggest Challenge:
Employee Eligibility Verification
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About Health Decisions, Inc.
Pioneering Specialists in Group Health CarePioneering Specialists in Group Health Care
Post-Payment AdministrationPost-Payment Administration
For Over 25 YearsFor Over 25 Years
RespectRespect for Existing Procedures for Existing Procedures
EmphasisEmphasis on Customization on Customization
FocusFocus on Solutions on Solutions
Customer Philosophy:
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2014 ACA Series
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Non-grandfathered, calendar year plans.
“Blue Collar” Compliance.Delays and technical intricacies no excuse.
Comply not just because you have to.Comply in a way that helps your plan.
FOCUS
2014 ACA Series
Month Current Focus
2014 ACA Plan Webinar Series
January
Prior Year Close-out
1/30: ACA is here. Are you ready?What you should have done and in place now.
February 2/20: ACA’s Biggest Challenge: Employee Eligibility Verification.Opportunity for savings and employee engagement.
March 3/20: ACA Taxes and Dependent VerificationHow much. How to minimize. How to manage.
April 4/17: ACA Cost Sharing (Preventive Care and OOP Maximum)Ticking time-bomb of liability.
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Quick ReviewWhat you should have done.
• Reporting to employees– W-2 plan values– Summary of Benefits and Coverage (SBC)– Exchange Notices
• Benefits– Selected Essential Health Benefits– No cost sharing for federal preventive care benefits– No pre-existing conditions– No lifetime maximums– Dependents covered until 26– Clinical trial coverage
• Safe Harbors– Minimum Value Safe Harbor – Affordability Safe Harbor
• New Out-of-Pocket rules implemented
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ACA Compliance
Self-Assessment Tool
available now.
Call 734-451-2230Ask for Leslie.
Quick ReviewWhat You Should Have in Place.
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Start NOW
CompleteFirst Quarter
Compile Needed Data Files o Payroll Data (with history)o Enrollment Rosters (with history)o Paid Claims (transactions not summaries)
Assess Data files for accuracy and use
Reconcile payroll facts with enrollment factso Expect major inconsistencies o Expect ineligibleso Expect late terminations
Survey all employees o Verify dependent eligibility for two ACA taxes in 2014o Collect SSN for ALL employees, retirees, and family
members o Two-way communication (authorizations & “good faith”
efforts)
• Confirm cost sharing controlso Preventive Services Zero cost sharingo Out-of-pocket maximum limits
ACA “Have To”
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“W-2” For Health Coverage
ACA requires employers to include in annual IRS filings:•The health coverage status of all employees:
• those with and without health coverage; • those eligible and not eligible.• By coverage type (single, two-person, family
•With month-by-month accounting.•Sent via electronic rosters meeting IRS technical specifications.•AND reports to each employee confirming what was sent about them.
2016 reports account for 2015
2014 testing best preparation for 2015 accounting
ACA “Have To”
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The IRS will •Compare these rosters to rosters from the new State Health Exchanges. •Use these rosters to enforce
• Individual subsidies and • Employer “shared responsibility”
Employers not complying face possible penalties and fines.•ACA•IRS
Reality of Employee Eligibility Verification
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There is no one place employers can go to get all the required information.
Employers have to piece together a reporting puzzle. •Payroll system vendors have pieces of the puzzle. •Group health plan administrators have pieces of the puzzle. •Enrollment maintenance and COBRA vendors have pieces of the puzzle.•Some puzzle pieces may be missing.
Puzzle pieces will not fit together easily.
Enrollment Payroll
No common IDInput errors
Different codesMissing data
No historyIncompatible systemsIncompatible layouts
…We’ve seen it all and it “ain’t” pretty.
ACA “Help Your Plan”
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Savings
What the Payroll/Enrollment Match Reveals
Excess Administrative Fees
Excess Insurance Premiums
Excess Stop-loss Premiums
Duplicate Payments and Fees
Claims Paid After Termination
Claims Paid During Coverage Lapses
Claims Paid for Ineligibles
Phantoms (Type 1):
Employees enrolled beyond termination date. Phantoms (Type 2):Unknown persons enrolled in one or more plans.Errors:
Employees enrolled who are ineligible.Duplicates:
Employees enrolled in multiple plans.Wrong Tier (Type 1): Single enrollees in non-single coverage categories.Wrong Tier (Type 2): Two-person coverage enrolled as family.COBRA:
COBRA enrollees not COBRA eligible.
Not “whether” but “how much”.
ACA Plan
This Month’s “To Do” List
Payroll and Enrollment: Combination/Reconciliation
•Start now to be ready to confirm what you can do.
•Start now to have time to fix what needs fixing.
•Start now to be ready 1/2015 and avoid penalties.
•Start now to get savings now.
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For More Information
Contact
734-451-2230
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