by: Mary Anne Giezentanner
June is fast approaching. For many people this brings the excitement of summer break, picnics, and family vacations. For those of us working in Human Resources, Benefits Administration, or Payroll departments, this means that we’re another month closer to the 2016 effective date of the employer mandate, or section 6056 of the Affordable Care Act (ACA). The mandate, which outlines requirements for the provision of healthcare benefits by employers with 50 or more full-time or full-time equivalent employees, packs quite a punch to employers with its onerous reporting requirements. The forms required under section 6056 are 1094-C, due to the IRS on February 29, 2016 and 1095-C, due to employees by January 31, 2016. Each form requires a combination of information regarding health insurance offer and coverage activities for the 2015 plan year from HR, Benefits, and Payroll.
I was curious to know how my colleagues in HR are preparing for the upcoming requirements. I conducted my own informal survey of sorts and asked around. The responses I received varied widely and included tactics such as pretending the requirements do not exist or taking the “wait and see” approach, assuming the broker will handle it, creating highly detailed and sophisticated spreadsheets with every bit of data available, and purchasing an integrated software solution. While there is no one size fits all approach to preparing for the ACA reporting requirements, one fact remains clear; the events on which we’ll be reporting in early 2016 are happening now. Somehow this data has to be captured, maintained and funneled into the reporting mechanism or process. Neither HR nor Payroll should embark on this reporting process alone.
So what can employers do to prepare? I picked up some good suggestions while discussing the upcoming reporting requirements with the brokers from JKJ Benefits, LLC. For companies where the responsibility of HR, Benefits, and Payroll administration spans over multiple individuals or departments, Barbara Jeffrey from JKJ recommends forming a committee with members from each of these departments. Through regularly scheduled meetings, the committee can determine if the necessary information is being collected, how and where it is maintained, and how it can be incorporated into the reporting process. Depending on the company’s methods of processing payroll and benefits, the committee might also seek input from their IT professional/consultant, payroll service provider, insurance carrier, or benefits broker.
Regardless of the company’s size and structure, Trina Jackson, also with JKJ Benefits, highlighted the importance of keeping upper management informed about the latest ACA developments and reporting requirements. The tasks involved in complying with the ACA are likely to require additional resources such as staff, work hours, training, and new or upgraded software. In order to allocate the necessary resources, management should be aware of what the ACA will require from employers as well as what tools will be needed to meet those requirements.
To be adequately prepared, HR, Benefits, and Payroll staff need to stay informed. Continuing education and training costs can quickly eat away at your budget. This is especially true with the ACA, as it is important to ensure that all involved personnel are well trained on this topic. To stretch your resources as far as they can go, do not forget to look to your business partners, service providers, and professional organizations for help. As Rise’ Kieren from JKJ pointed out, many insurance carriers and brokers are offering educational materials and webinars for employers at little or no cost. The ACA Employer Mandate is also a hot topic for newsletters, legislative updates, webcasts, and luncheons sponsored by professional organizations like the Society for Human Resource Management (SHRM). Additionally, look to your payroll service provider or business partner for tools already available to you to automate the reporting process. Tools like My Workforce Analyzerfrom Sage Software work with your existing HR and payroll system to ease the reporting burden by combining data from both systems and populating the various forms. For more information on My Workforce Analyzer and other ACA resources, visit CS3 Technology’s ACA Hotspot.