A large percentage of employers still have not decided how they
are going to comply with the Patient Protection and Affordable Care
Act’s (ACA) information reporting requirements, according to
speakers at a recent Mercer webcast entitled ACA Play-Or-Pay
and Minimum Essential Coverage (MEC) Reporting. Employers
will be required to do either Section 6055 or Section 6056 (and in
some cases, both) reporting for the 2015 plan year. While the forms
are not due to the IRS until early 2016, it is important for employers
to determine the processes they want to use to comply with these provisions
Section 6055 requires every health insurance issuer, sponsor
of a self-insured health plan, government agency that administers
government-sponsored health insurance programs, and other entities
that provide minimum essential coverage to file annual returns reporting
information for each individual for whom such coverage is provided.
Section 6056 requires applicable large employers–generally employers
with at least 50 full-time employees, including full-time equivalent
employees–to file information returns reporting the terms and
conditions of the health care coverage, if any, provided to full-time
According to Tracy Watts, senior partner at Mercer, when these
requirements were first announced, most employers believed that they
would meet the ACA’s information reporting requirements in-house,
but “as we’ve learned more and more about the reporting
requirements, this has changed.” Now, Watts noted that more
employers are unsure as to how they will comply with the requirements,
and another “substantial percentage” of employers believe
they will use a third party to meet these requirements.
During the webinar, Watts outlined five steps to compliance:
• Review required data elements. The first
step is to review the data needed to fill out these forms. Watts indicated
that at the beginning of this process, it is important to think about
what departments/divisions in your company that might be able to contribute
towards compliance. “You shouldn’t feel that this is something
that the HR/benefits department in your company has to go at alone,”
she noted. Some departments with a vested interest in this would be
the payroll department (or payroll vendor), the finance department,
and in-house counsel.
• Locate your data. The experts at Mercer “think
that [locating the necessary data] is the challenging part of the
reporting requirements because it’s not likely that all of the
data elements you need are going to be housed in the same place,”
said Watts. For example, an employers’ health plan administrator
will have to provide information on actual enrollment and dependent
data, and the payroll vendor will have to provide information about
full-time status and the affordability of the plans offered to employees.
• Determine your vendor capabilities. There
are some important questions you need to ask, according to Watts:
Is your payroll vendor offering a solution to help complete the required
forms? Do you want to buy the reporting support only or do you want
a bundled solution, which would include hour tracking as well as reporting?
Or do you want to forgo the use of a vendor and do this in-house?
Finalize responsibilities. The next step is to actually decide who will: aggregate your data, complete the forms, deliver the individual statements and transmit the data to the IRS. Also, employers might want to decide who will be responsible for responding
to the Health Insurance Exchange notifications, Watts said.
Begin tracking. “And get ready to Report,” Watts concluded.
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