No harm in reminding one and all that you have until March 1 — according to the recently enacted Affordable Care Act — to notify your employees about state-specific healthcare exchanges to be set up before 2014.
This alert from the Society for Human Resource Mangement lays out what you need to be doing next, according to the new law, after you’ve satisfied your January 2013 healthcare-benefit cost-reporting requirement for 2012 W-2s, that is. (Appropriate informational links are included in the SHRM piece; note, though, that the SHRM site is a subscription-based one.)
In the piece, Jennifer Benz, CEO of Benz Communications, lists three specific communication requirements employers must satisfy by March 1:
• State exchange basics. This is a description of the state exchange, the services provided by the exchange and how to contact the exchange (website and customer service number). One wrinkle: not all states have decided how they’re going to comply (the National Conference of State Legislatures provides an up-to-date chart of state implementation efforts). Employers in multi-plan states will have an even more challenging time.
• Individual plan value. This explains whether employees will receive at least 60 percent coverage of essential health benefits through employer-provided coverage, and whether employees may be eligible for a premium tax credit if they purchase a plan on the state exchange.
• Tax implications. Because health-insurance premiums under employer-sponsored coverage may be paid with pre-tax dollars, buying coverage through a state exchange may change an employee’s tax obligations. Employees using an exchange to purchase coverage may lose their employer’s tax-free contribution (if any) to their health coverage, also.
Although many benefits and HR experts are predicting the March deadline will be extended, considering the U.S. Department of Labor has yet to release proposed regulations or samples of a model notice, Benz suggests integrating the three-part notice into your overall health-benefits-communication strategy regardless.
“No matter what deadline the DOL ultimately sets,” says Benz, “employers need to be prepared to include [these three points] in their communication plans for 2013.”
“Communicate your 2014 position before the legalese does,” she adds. “Be sure to use language that fits the notice into your big-picture approach to healthcare-reform compliance. For many employers, this strategy is going to include high-deductible health plans and incentive-heavy wellness programs, two benefit strategies that require robust, thoughtful communications in their own right.”