Most large employers are aware of the potential “Pay or Play”1 penalties of the Affordable Care Act (ACA) that they will be facing starting January 1, 2015, assuming no postponement in the current timetable. However, are these employers also aware of the many other pitfalls and penalties that they will face if they fail to be completely ACA compliant? Chances are that whatever methods, systems, or software an employer is using, it won’t be able to easily attain all of the data necessary for ACA compliance requirements. To avoid penalties, large employers will need systems that are capable of tracking employee hours, benefit eligibility, dependents, waiting periods, health care coverage offerings, and enrollment by lines of coverage. Even employers electing NOT to offer medical coverage will be required to send notices and reports to employees and the IRS. For employers with fluctuating work schedules, such as restaurants and health care providers, gathering this information can be difficult, time consuming, and expensive.
To successfully comply, information gathering and accurate reporting automation will be critical to assimilating all such vital information and to dispensing it to employees and required reporting agencies. The challenge facing employers is that they may not have immediate access to the data required to be compliant. Further, the data may be unavailable, unusable, or of questionable accuracy. Even with the right data, employers’ data gathering and compilation systems face new challenges to conduct proper analyses and to satisfy stringent ACA reporting requirements. The new systems will need to have the capacity to deliver actionable information, track, forecast, and manage costs and trends, and still meet reporting requirements. For public firms auditability is also important under Sarbanes-Oxley requirements. An automated system that accurately provides all of the required information is essential to ACA compliance. Non-compliance, even unintentional, can be expensive, trigger audits, and disrupt business operations. A system that provides centralized data and communicates changes instantaneously and accurately between HR, payroll, benefits, carriers, and third party administrators is essential in this new world dictated by the ACA.
What challenges do you face in meeting the 2015 ACA reporting requirements? What steps have you taken?
 U.S. employers under the Affordable Care Act (ACA) must make many decisions. Most importantly, at this time, is to decide whether it is financially and competitively advantageous to offer health coverage? This decision is called “Pay or Play”.