Employers had to comply with many Patient Protection and Affordable Care Act (PPACA) provisions — including the young-adult coverage access provisions, the Summary of Benefits and Coverage (SBC) provisions, and the provisions phasing out annual and lifetime major medical benefits limits — even before Jan. 1, 2014.
More notice requirements crept in shortly before and during 2014.
In 2015, many employers will start to learn more than they’d like about many different PPACA coverage and reporting requirements, such as the PPACA employee counting and coverage reporting rules.
The federal agencies in charge of PPACA compliance — the U.S. Labor Department’s Employee Benefits Security Administration (EBSA), the Internal Revenue Service and the U.S. Department of Health and Human Services (HHS) — have talked mostly about warm and friendly efforts to help helpful and enthusiastic employers fulfill their PPACA compliance obligations.
The officials have also mentioned, in passing that they are getting ready to supplement employers’ enthusiastic compliance efforts by conducting audits.
Compliance analysts at ACAtrack.net, a PPACA compliance automation firm, have recently created a helpful slide deck discussing the EBSA PPACA audit program.
For highlights from the slide deck, read on.
1. EBSA has set up a Health Benefits Security Project team to handle PPACA enforcement.
Getting numbers is difficult, but EBSA said in 2010 that it was hiring about 670 new investigators to help with matters such as PPACA compliance audits. By now, hundreds of those new hires should be on board, trained, and ready to investigate.
EBSA also said it was setting up a Health Benefits Security Project (HBSP), and Labor Department officials have talked about a need for cash to fund the HBSP in congressional hearings.