The clock is ticking on the amount of time employers have to figure out their ACA game plan. Many employers gave a sigh of relief as they thought the pressure to deal with the complicated regulations surrounding their workforce strategy was lifted from their shoulders when the Employer Mandate was delayed by one year, now set to begin on January 1, 2015.The truth is this delay did not lessen the burden and complexity that comes with the ACA provisions, if anything it has only made it more difficult to understand as employers try to apply the regulations to unique employment situations within their organization. It is extremely important for employers to realize that in order to fully comply with the Employer Mandate, an employer must actually be tracking employee information prior to January 1, 2015.
The following are just a few of the steps employers should already be doing in order to make sure their systems are in place to comply:
- Employers must begin tracking employee eligibility for the 2015 enrollment year - this includes standard, administrative, stability, and initial measurement periods for employers using the look-back safe harbor
- Employers must account for leave of absence and breaks-in-service when calculating an employee’s hours of service to determine full-time status
- Even for employees who are paid per project or visit, an employer must calculate the hours worked equivalency
- Notices to each employee with information regarding their healthcare options are required to be distributed to new employees within 14 days of hire
Although the ACA reporting requirements for section 6055 and 6056 have yet to be finalized, it is highly anticipated these factors will be necessary in order to properly report the required information. With the Employer Mandate less than a year away, the amount of time employers have to define full-time employees, define solution needs and evaluate current systems, is quickly passing. For employers to ensure compliance tomorrow, they must start today.