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2015 PPACA compliance checklist

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More Patient Protection and Affordable Care Act (PPACA) group health provisions are supposed to begin taking effect in 2015.

The current schedule calls for a transitional version of the PPACA “play or pay” employer coverage mandate to apply to employers with 100 or more full-time employers, and to some employers with 50 to 99 employees.

Employers will have to keep track of which employees were offered health coverage in any given month, and large employers will have to put the employee count data they collected in 2014 into Internal Revenue Code Section (IRC) 4980H “employer shared responsibility” reports.

See also: Nitty-gritty on 6 key provisions of employer mandate

Meanwhile, some of your employee clients may still be scrambling to create, and understand, their PPACA compliance checklists. What should those clients be doing to make sure they’re ready for 2015?

For a list of five action items your clients should focus on now, read on.

Tape measure

1. Review existing measurement systems.

Are your clients equipped to determine employee status, while considering measurement and stability periods, to provide coverage as soon as an employee becomes eligible?

See also: 15 PPACA provisions that will take effect in 2014

Dollar bill puzzle

2. Determine excise tax penalty risk by entity.

Your clients should identify potential full-time employees not offered coverage.

See also: Experts worry about IRS pitfalls

Abstract process image

3. Assess reporting systems.

Are your clients’ reporting systems capable of gathering and aggregating the required information for IRS reporting – by employee, on a by-month and by-entity basis? Reports are due to the IRS in 2016, but data collections begins January 1, 2015. How do companies manage data residing in multiple locations? This is especially difficult for employers with a contingent or variable workforce.

See also: The employer mandate and family-owned businesses 2015

4. Prepare for Marketplace/Exchange notices.

In November, open enrollment begins and even businesses offering affordable care to employees are likely to receive Marketplace notices. Notices must be analyzed for accuracy and any erroneously issued notices must be appealed within the designated timeframe – which can vary by state (typically 90 days).

See also: IRS redesigns PPACA coverage notice drafts

IRS offices

5. Develop a plan for IRS assessments.

Will your clients be able to provide supporting analysis and documentation to defend against erroneous assessments?

EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. The views expressed are those of the author and do not necessarily represent the views of EY.

See also: Mercer projects PPACA penalties