If you were in the Olympics would you go for last place, Bronze, Silver or, go for the Gold? My guess is that you would go for GOLD! To win Gold, you need to train daily, have a great coach, stay on top of your game, and be the best. There is no shortcut to get to that Gold medal for Affordable Care Act (ACA) compliance. Are you crossing all your t’s and dotting all your i’s?
Here are a few key items to review and master in your compliance routine:
Tracking employee hours
If you thought tracking hours only applied to hours shown on a paycheck, well, you may want to have a discussion with your current coach. Service hours include hours worked and paid (no brainer there), hours not worked and paid (vacation, sick, PTO, holiday, on-call), and hours not worked and not paid. If you just said, “Huh?” then it’s time to get back to the gym and work on your form. These include hours an employee was off for jury duty, military leave, FMLA, or disability. Have adjunct faculty? Your routine has just entered into a high degree of difficulty.
Your payroll system may be pulling paid hours into a report for you to track, but what about the unpaid hours? “Why does it matter” you ask? Service hours determine the status for employees within a measurement period which, in turn, impacts offers of coverage and stability periods. These hours could mean that an ongoing employee who wasn’t previously eligible is now eligible for benefits due to their cumulative service hours.
Determining full-time status
How do you determine the full-time status of your employees? Have you established the measurement, administrative and stability periods you need specific to your workforce? Are you using a look-back or monthly measurement? Do you know what to do if an employee has a reclassification from full-time to part-time? Are you offering coverage on time to all full-time employees? With the compliance threshold moving to 95 percent in 2016 there is little room for error. If you are not, you could be opening yourself up to penalties.
Managing your data
Last, but not least, is data. Data management is at the heart of ACA compliance. Have you reviewed your data lately? Many organizations struggle with the “garbage in, garbage out” phenomenon. If what you are entering into your ACA solution is wrong, your tracking and reporting will not be correct. With penalties assessed monthly, you may already be in last place thinking you’re on track for Gold! Give yourself a periodic check-up. If ACA data is spread out over multiple departments (which is often the case), make sure your team is working together and verifying the accuracy of data.
ACA requires constant, marathon-like attention. Treating compliance as a sprint in December certainly won’t help you obtain Gold! If you have a variable hour or seasonal workforce, you should be in training mode year-round.
About Lisa Slook
Lisa Slook, CHRS, PHR, SHRM-CP, CEO of 1095HelpDesk.com is here to assist you in your ACA journey. From project work to full-service administration, she created the company to provide clients with the ACA support they need. The company focuses on compliance associated with the Employer Shared Responsibility and Reporting Requirements aspects within the Affordable Care Act.