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Michelle Northey, Senior Director, Product Management & Product Marketing, Health Care Reform, ADP
Within many organizations, there is a common misconception that compliance with the Affordable Care Act (ACA) is someone else’s responsibility. The truth of the matter is that ACA compliance demands hit all departments throughout an organization, from human resources and payroll to finance, legal and even Information Technology (IT).
Having rewritten the rules of U.S. workforce management, the ACA is one of the biggest issues facing employers today. It has transformed what was once an annual health care benefits enrollment event into an ongoing process of tracking and reporting extensive data sets for every employee.
To meet complex ACA requirements, employers need a technological framework that can extract and merge data from disparate systems to perform calculations required to show compliance with ACA mandates. To do this, IT systems must seamlessly coordinate among multiple business units and functions.
Synchronization is key to generating Health Insurance Marketplace documentation, IRS filings, penalty estimates and other data that must be reported to the state and federal government. In fact, our research found that most decision makers involved in ACA compliance cited “fast and easy access to employee data” as “extremely important” in driving their section of a compliance solution.
Unfortunately, the costs will be high for those who are unable to meet this significantly increased burden in data collection and reporting. Initial penalties for non-compliance go into effect in 2015 and they could range into millions of dollars for organizations that are unprepared. The time to plan and act is now.
Here are seven tips to help IT managers contribute to an ACAcompliant environment:
"For IT leaders to succeed, they must first acknowledge the importance of a comprehensive, data-driven approach to ACA compliance"
• Coordinate with other departments to determine all of the data sets needed to meet compliance and map out where the data is housed. Large employers will need to integrate data from multiple workforce management platforms, including human resources, benefits, work time, leaves of absence, payroll, and Form I9 data.
• Launch a thorough review of system, network and software capabilities to determine whether the right tools are in place to merge, calculate and report the necessary data. If not, identify which systems need to be updated, supplemented or replaced.
• Store the data once it is aggregated—in some cases, for many years. Given that ACA penalties come in the form of a tax levy, employers need to be prepared to accommodate any future information requests from the IRS. If any data have been compromised, employers may face a barrage of correspondence and complaints. Additionally, faulty or inadequate information sent to the IRS may result in reporting penalties up to $100 per occurrence and a maximum of $1.5 million.
• Store information securely and share it securely, too. In some cases, employers will need to share employee data with Health Insurance Marketplaces and the IRS to confirm adherence with the law’s affordability requirement. Because transfer of this data can potentially expose employers to Health Insurance Portability and Accountability Act (HIPAA) violations, IT must ensure the necessary tools are in place for secure transfer.
• Prepare for the IT demands unique to your industry and business model. For example, organizations with primarily hourly workers, such as retail and restaurants, will have much higher populations that can claim premium tax credits because their employers may not provide access to affordable minimum coverage.
• Remain nimble and flexible enough to accommodate rule changes and state-specific regulations. Currently, 16 states and the District of Columbia have developed their own Health Insurance Marketplaces. IT managers will need to prepare to meet the unique requirements of each of the states in which the organization does business. The regulatory environment will also likely remain extremely fluid as the ACA continues to be defined and refined through new regulatory guidance or legislation.
• Consider partnering with a third-party that understands ACA compliance and the independency of ACA data sets to mitigate compliance risks. By choosing a partner that can build and support an infrastructure dedicated to ACA success, organizations are free to focus on their core business and grow top-line revenue while protecting themselves from bottom-line ACA penalty impacts.
There is no doubt that IT leaders will play an essential role in their organization’s successful navigation of this seismic shift in workforce management. A company’s IT infrastructure and valuable employee data are the first lines of defense against ACA penalties. For IT leaders to succeed, they must first acknowledge the importance of a comprehensive, data-driven approach to ACA compliance. With the right infrastructure in place, organizations can minimize inefficiencies, prevent burdensome administrative hassles and avoid millions of dollars in potential financial penalties for non compliance.