Employer Checklist for ACA Action Items

By Tobias Kennedy, Executive Vice President, Montage Insurance Solutions

With so many health care reform law changes and updates, human resources professionals and companies are asking for a boiled down version of some of the main points that need to be highlighted, regarding the Affordable Care Act (ACA) and key pending action items.

Smart Business spoke with Tobias Kennedy, executive vice president, Montage Insurance Solutions, about what you need to know and do with the ACA.

What are a couple of immediate concerns for everyone?

First and foremost, make sure you got your notice out to your employees on their rights to the new marketplaces, or exchanges. Then, make sure the notice gets added to your new hire kit for future staff.

Next, employers need to look at their waiting periods and their compliance with California’s Assembly Bill 1083, which is a state law that expounds a little on the ACA. If this law applies to you, you may need to clip your waiting period if it extends beyond the allotted 60 days. Be aware this is separate than the federal bill and is set for a 2014 start date.

What extra steps do large employers need to take?

To find out if you need to comply with the employer shared responsibility provision, you have to evaluate your employees. Basically, the question is: Do you employ an average of at least 50 full-time people, including full- time equivalents. For some groups, this is an easy question. Others may waiver near the border, so it’s important to know the correct method for calculation.

If you do trigger the shared responsibility provision, you now need to be aware of exactly whom you are supposed to be offering benefits to, and exactly what types of benefits will qualify.

How should large employers keep track of their employees’ hours?

It’s a good idea for employer groups to start doing a regular check — monthly, quarterly, etc. — to see which employees are being offered coverage versus which employees are averaging more than 30 hours per week. Remember, just because you think they’re part-timers doesn’t mean they aren’t a manager’s go-to when someone calls in sick, or the workload gets hefty. It’s not uncommon for overtime hours to add up and alter a person’s average hours worked.

You’ll want to have a handle on the average hours worked by people that are not offered your benefits by running a payroll report and watching out for staff who edge up near the 30-hour average mark.

What’s key to know about insurance renewals?

You will want to note that, beginning with the upcoming January 2014 renewals, this is your last renewal to come into compliance before facing fines. Are your plan designs compliant? Is your employer/employee premium split compliant? If not, you may want to see where you are versuswhere you need to be. You’ll need to see what, if any, transitional steps you want to take this renewal, so you’re not so far off in 2015 when the potential for fines enters the picture.

Tobias Kennedy is an executive vice president at Montage Insurance Solutions. Reach him at 1 (888) 839-2147 or [email protected].

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