Employers are receiving automated emails from the MA Department of Revenue’s MassTaxConnect notifying them of a new health insurance reporting requirement and indicating that action is required. Welcome to the new annual Employer Health Insurance Responsibility Disclosure (HIRD) filing requirement. Here is a quick start overview of the requirement.
STATE LAW NOW REQUIRES EVERY EMPLOYER IN MASSACHUSETTS WITH SIX OR MORE EMPLOYEES to annually submit a HIRD form each November, commencing with November 2018.
- The due date of the form is November 30, 2018 (and by each November 30 thereafter).
- The HIRD reporting is administered by MassHealth and the Department of Revenue (DOR) through the MassTaxConnect (MTC) web portal
- Although only one HIRD form per employer is required, employer groups must report a separate HIRD form for each FEIN because MTC login credentials are tied to FEIN, so the employer must log into each FEIN MTC account they have and complete a HIRD form for each account
EMPLOYERS THAT CURRENTLY HAVE (OR HAD) SIX OR MORE EMPLOYEES in any month during the 12 months preceding the due date of the HIRD is form (November 30th of the reporting year) are required to complete the HIRD form.
AN INDIVIDUAL IS CONSIDERED AN EMPLOYEE of the employer (employed in any employment category) if the employer included the individual in any quarterly wage report to the Department of Unemployment Assistance (DUA) during the 12 month reporting period.
THE PURPOSE OF THE HIRD FORM is to collect employer-level information about its employer-sponsored health insurance (ESI) offerings.
- Employers are not required to report information about HRAs, health FSAs or HSAs on the HIRD form
- Employers who do not offer health insurance are required to log into MTC and submit the HIRD form
- There are no fines or penalties resulting from the information submitted on the HIRD form
THE GOAL OF THE HIRD FORM is to inform MassHealth about employers’ ESI offerings and assist MassHealth in identifying its members with access to qualifying ESI who may be eligible to enroll in the MassHealth Premium Assistance Program.
THE ULTIMATE GOAL of the new HIRD form is to allow more MassHealth members to enroll in the MassHealth Premium Assistance Program.
THE HIRD FORM MAY BE FILED ON MTC BY EITHER THE EMPLOYER OR ITS PAYROLL COMPANY; however, it’s the employer’s responsibility to ensure that the HIRD form is timely filed. If using a payroll company to file on MTC, the employer should coordinate HIRD reporting between the payroll company and the employer’s record keeper for health insurance information. Chances are the payroll company will not have the type of information necessary to complete the HIRD form.
A BENEFIT TO EMPLOYERS is that:
- Employees enrolled in MassHealth’s Premium Assistance Program, are not included in the calculation of their employer’s obligation under the Employer Medical Assistance (EMAC) Supplement
- Employees enrolled in ESI and receiving MassHealth coverage as a secondary payer are not included in their employer’s obligation under the EMAC Supplement
THE HIRD FORM WILL NOT BE USED:
- In connection with any determinations regarding employers’ EMAC Supplement obligations
- To impose any new fines or penalties related to employers’ ESI offerings (or lack thereof)
- To collect any personal information about employees
THE MASSHEALTH PREMIUM ASSISTANCE PROGRAM helps eligible working individuals and families pay for qualifying ESI coverage. Eligible MassHealth members with access to qualifying ESI are required to enroll in available ESI. Members who are determined eligible for Premium Assistance may enroll in ESI without regard to any enrollment periods or other restrictions that apply to late enrollees for any group plan, as the MassHealth eligibility determination is considered a qualifying event. Information on the MassHealth Premium Assistance Program can be found on the MassHealth Premium Assistance web page: (https://www.mass.gov/service-
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Richard A. Szczebak, Esq. 781-731-9933 | [email protected] Experience | Knowledge | Perspective
The foregoing has been prepared for the general information of MassAHU members. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel. This material may be considered advertising under certain rules of professional conduct.
• A Health Care Legislative and Election Update;
• Putting the Benefit Back in Benefits and Giving Employers a Break;
• How to maximize your EBIDA by treating your health plan as a capital allocation strategy;
• Claims Administration, Enrollment Management and Compliance;
• HR moving from administrative tasks to strategic value through technologyWhen
November 2, 2018
8:30 AM –11:30 AM
Presentation and an interactive panel discussion
Includes breakfast and networking
100 Cabot St,
Needham, MA 02494
To register, please go to the following link:
We hope to see you there!
When: Tuesday, September 18th at 9:30 AM EDT
Presented By: Matt Hollister and Jim Edholm
Please register by email to [email protected] by September 10th.
Massachusetts recently enacted a new, mandatory paid Family and Medical Leave program (MAFML) to be administered by the Commonwealth and funded by employer and employee contributions through a .63% (.0063) payroll tax on wages. Although the first MAFML benefits are not available until January 1, 2021, a program of this magnitude will take time to implement and pre-fund.
While the new MAFML is a government program administered by the Commonwealth, it creates both compliance and cost considerations for employers as well. Please join us on Thursday, August 30, 2018 at 2 PM for a timely, one hour live webcast examining the new MAFML requirements and benefits. MAFML will impact current employer leave policies and procedures and will increase employer costs of doing business via contributions, additional administrative burdens and extended medical benefit coverage for those employees on leave.
Our featured Speaker will be Rick Szczebak, Esq. of RAS Law, P.C
To register for this webinar, simply click on the link below!
When: Thursday, August 30th at 2:00 PM EDT
Presented By: Rick Szczebak, Esq. of RAS Law, P.C
After registering, you will receive a confirmation email containing information about joining the webinar.
View System Requirements<https://link.goto
Model Notice Informs Employees of Eligibility for Premium Assistance Under Medicaid or CHIP
The U.S. Department of Labor (DOL) has updated its model notice for employers to provide information on eligibility for premium assistance under Medicaid or the Children’s Health Insurance Program (CHIP). This notice is generally updated twice a year. Click here to download the updated notice in PDF format.
Annual Notice Requirement
The updated model notice includes information on how employees can contact their state for additional information and how to apply for premium assistance, with information current as of July 31, 2018.
Our Benefits Notices by Company Size section features information on additional health plan notice requirements.
At the end of June, Massachusetts Governor Charlie Baker signed into law the “grand bargain” bill. This bill has a significant effect on the state’s minimum wage, which will ultimately rise to $15 an hour over 5 years. The bill also includes a paid family and medical leave program, which will be implemented by 2021 and will ultimately change the way employers approach insured short term disability programs here in Massachusetts.
The law incrementally raises the current $11-an-hour minimum wage to $15 an hour from 2019 to 2023. Beginning in 2019, the state minimum wage will go up to $12 an hour and will continue in 75-cent increments each year from then on: $12.75 in 2020, $13.50 in 2021, $14.25 in 2022, and $15 in 2023. The minimum base wage rate for tipped workers will also increase over five years, starting in January 2019 to a maximum of $6.75.
Paid Family and Medical Leave
Beginning in 2021, Massachusett’s Paid Family and Medical Leave program will be implemented. This gives contributing employees up to 12 weeks a year to care for a family member or bond with a new child, 20 weeks a year to handle a personal medical problem, and up to 26 weeks to handle an emergency relating to a military family member’s deployment. Weekly benefits will be based on a percentage of employees’ average weekly wages, with $850 a week being the maximum payout. The law allows self-employed workers to opt into the program. However, for the program to cover municipal workers, cities and towns must vote to participate.
As new information and ultimately the regulations for this new law are developed, we will continue to keep you informed.
We are very pleased to announce two new additions to our staff in Concord: Chloe DiPetrillo, who is working as a intern for the summer, and John Baumer, who comes on board as a Senior Account Executive.
Chloe is studying finance and marketing at Washington University in St. Louis, with a minor in global health. Chloe’s enthusiasm and fresh perspective is a tremendous benefit to our staff!
John’s career has spanned over two decades with Harvard Pilgrim Health Care where he has been in sales, sales management and training for Harvard’s sales and support teams. John is an effective communicator with a passion for customer service. John’s extensive experience in health insurance is a valuable asset and we feel he will be a great addition to our team.