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It’s that time of year again! The outside air is turning crisp. Football is on TV all weekend. And, unfortunately, not a single HR tech or benefits professional has any time to enjoy this wondrous season! After all, this is implementation time. There are project plans to move along, deadlines to meet! I think Shakespeare said it best in Hamlet: “By the prickling of my thumbs, something evil this way comes… open enrollment season is fast approaching.” Or something like that.

My teammates are all buried in various implementations around the country, but they are also collecting insights (battle scars) that may be great tips to help your company’s HR efforts. One of those comes from our favorite San Diegan, Paula. She’s working with a company on an HRIS install (you know, the all-in-one systems where HR, payroll and benefits share the same database) and, as is often the case, the company she’s working with has found its benefits module lacking – particularly on the issue of “waived” coverage.

Here’s one of Paula’s tips for benefits /Affordable Care Act (ACA) Reporting:

“I am continually amazed at how many systems do not set up ‘waive‘ as its own [plan choice] option, on the back end, which would make any kind of reporting much simpler. This system, and many others, does not do this or track the reason for an employee waiving coverage. I have been recommending this on all recent implementations so there is a trail for any types of appeals.”

I thought this was a great tip – especially once the ACA roll-out settles down and the IRS starts assessing penalties for employers not offering “qualifying and affordable” coverage. After all, in the years to come, many of our wonderful blog readers may receive letters putting their companies on the hot seat and asking them to prove they offered coverage for full-time employees.


One option you may want to explore is putting together a process around waived coverage. The way Paula has set it up is both a system change and a process change. She used a combination of the benefits election screens, a report writer and a communication portal to build out a process that will empower this employer to vigorously defend any IRS inquires. You may want to look at doing something similar. Having waive set up the same as other plan options can provide a full census of active and waived elections, whereas in most systems these are separate reports.  This can also help track active employees who waive a portion of the year and have coverage another portion as this will need to be reported on the 1094/1095 forms each year.

If an employee chooses the option of waive coverage through the enrollment process, they are sent a form letter (since this system can’t do an additional data collection task in the midst of its open enrollment wizard.) Dependent on system capabilities, the letter can display once the option is waived, can be accessed via a resource library or be sent directly from HR. The letter has two parts: data collection and education. As you can see in the illustration, this employer now can get feedback on why the employee waived coverage. Was it due to a spouse’s plan? But what I really like is the “consequences” section where the ACA impacts are fully explained.

Now, every situation and system is different, but I thought this might be a helpful example of how system setup – or alas, manual process – can be used to mitigate a potential risk. What great project management! Of course, you would certainly want to check with your vendor, broker and/or legal counsel on the best strategy for your workforce.

We truly wish you the best during this implementation season and hope you’ll send in your best stories, frustrations or system praise so we can share. Subscribe to this blog by clicking the nearby button to get regular updates. By the way – if you’ll be at October’s HR Technology conference, I’ll see you there. If any of you would like me to research any vendor, system or issue while there, please know I’m always happy to help.