A lot has been going on the past few weeks: the Anthem data breach followed by the phishing scam of those same victims and then the IRS delivered the final instructions for ACA reporting forms. If you weren’t aware of the employer requirements for the Affordable Care Act, the release of the final reporting forms confirms that employers will be required to collect a massive amount of data.

For employers, the IRS released the final versions of Forms 1094-C and 1095-C and instructions for completing them. For insurers, the IRS also released final versions of Forms 1094-B and 1095-B with instructions to report minimum essential coverage.

What does this mean for employers?

Employers should start talking with their HRIS vendors now to determine what data is already being collected or if they will need to seek out an ACA technology system to facilitate the collection of the data required for the 1094-C and 1095-C forms.

In our experience, each HRIS vendor may have some capabilities to help their clients with ACA compliance.  However, not many vendors can help support a client with all of the required areas of compliance.  In addition, each employer must find out if they are capturing the required information, (i.e., Offer of Coverage Codes, Safe Harbor Codes, names and social security numbers for each covered individual, leave/absence management information, etc.) which is not likely captured in current technology solutions.  Employers must find out if this data will need to be manually entered into a system, form, or software, how they will do this, and how they will ensure the integrity of this data.

The HR Technology & Outsourcing Practice has outlined a list of questions each employer should be asking their current HR technology vendors with regards to their readiness to aggregate the information required to populate and distribute the forms, as well as help with other areas of ACA compliance. Depending upon their response, a stand-alone ACA tracking solution may serve a client well.

Questions each Employer should ask their current HRIS Vendors
How can you help me with ACA compliance related to:

1. Hours tracking and measurement?
2. Determination of eligible employees?
3. Initial Notice of Exchange?
4. Affordability?
5. How are you ensuring I am capturing required data?
6. Aggregating data from my disparate HRIS systems (HR, Payroll, Benefits Administration and Leave Administration)?
7. Populating the required IRS forms?
8. Distributing forms?
9. Exchange Notification log and response?
10. Storing aggregated data for seven years?
11.  Audit reconciliation?
12. Mechanics:  Are you pulling data from my other vendors or am I sending to it you? Is data pushed to me or am I running reports? Am I sending the forms or are you?

How do you feel about the final forms release? How do you feel about the reporting requirements? If you have any questions about ACA reporting requirements and how technology can help, let us know!