Home > Employee Benefits > 2015 Compliance To-Do’s: Is your checklist ready?

2015 Compliance To-Do’s: Is your checklist ready?

aca_magnifying_glassAs 2014 winds down, employers are longing for a reprieve in benefits compliance after having to endure a year of new, often times complex, guidance related to the Affordable Care Act (ACA), HIPAA and same-sex spouses. Unfortunately, to-do lists are only going to get longer as employers review their plans and get ready for the approaching challenges and deadlines arising in the upcoming year. Below is a summary of three main compliance issues for employers to keep on their regulatory checklists in the coming year.

  • Affordable Care Act:
    • Transitional Reinsurance Fee: Self-funded plans must send HHS head count information no later than November 15, 2014. Payment will be due in two parts, once in January 2015 and the remainder in December 2015.
    • Play or Pay-Employer Mandate: As of the first day of the 2015 plan year, employers with 100+ full-time employees must offer minimum value, affordable coverage to full-time employees (30 hrs/wk) or be subject to a penalty.
    • Reporting of coverage to IRS: Plan sponsors will report to the IRS the health coverage offered to employees for the 2015 calendar year in early 2016. Therefore in 2015, employers should capture the necessary information for the IRS forms, including the SSNs of each individual on the plan.
  • HIPAA
    •  Health Plan Identifier (HPID): Self-funded plans must obtain an HPID by November 5, 2014. It is important to note that self-funded plans with annual receipts of $5 million or less will have until November 5, 2015 to get an HPID. Also, HRAs that cover deductibles only or out-of-pocket costs do not require HPIDs. Carriers will apply for the HPID on behalf of fully insured plans.
    • HIPAA Electronic Transaction Certification: Self-funded plans will certify to HHS that HIPAA standard transactions are in compliance with HIPAA rules by December 31, 2015. Small health plans may have additional time to comply.
    • Documents: Ensure HIPAA privacy documents and updated Business Associate Agreements are in place.
  •  Plan Documents
    • Reflect full-time employee definition as 30 hours/week for medical coverage and outline measurement periods, if subject to the employer mandate.
    • Update documents to reflect same-sex spousal rights, including FMLA policies.
    • Amend cafeteria plan documents to include new permitted election changes related to when an employee can drop a plan mid-year. This may be due to a reduction in hours below 30 hrs/week, or due to enrollment in a Marketplace plan.

Depending on their plan design and size, employers may be subject to one or more of these items. Feeling overwhelmed? Unfortunately, avoidance is not the answer. Proactive planning, however, is a great solution, so employers can take action now by compiling a checklist and formulating an effective strategy for each compliance matter.


About the Author

Priya Setty is an Assistant Vice President in the Employee Benefits Group at William Gallagher Associates. Her role involves educating and providing compliance guidance to clients in applicable local, state and federal regulations affecting their insurance programs and employees. She is also a member of WGA’s Health Reform Advisory Committee.

617.646.0216 | PSetty@wgains.com | Connect with Priya on LinkedIn
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