Seven ACA Subsidy Best Practices

By Jennifer Eaves, Senior Director, Product Marketing, Equifax, Charleston, SC.

Benefits Specialist Magazine, Jan/Feb 2017

While the future of the Affordable Care Act remains uncertain, employers can (and should) expect the 2017 to bring additional complexities related to ACA premium tax credits (subsidies). With health insurance premiums on the rise and millions of new consumers enrolling in coverage through HealthCare.gov, more and more Ameri­cans will inevitably be eligible to receive subsidies to help pay for coverage through an exchange.

For those who receive a subsidy, noti­fications will be sent to their employer. A large batch of these notices is expected to come soon after open enrollment ends on January 31. Processing these notices—and potentially appealing them—could mean resource constraints, penalty exposure and additional needs for your clients, so you’ll want to make sure you know how best to advise them.

We’ve compiled a list of seven best prac­tices for employers to keep in mind when dealing with subsidy notifications and ap­peals. Check them out and share these tips with your clients:

  • Educate, Communicate and Train.

HR and benefits leaders will want to help employees and field HR staff understand key pieces of information about the subsidy process. Employers may wish to consider providing helpful resources to answer basic questions about how the subsidy process works, what is considered “affordable” healthcare by the law, why you may appeal a subsidy and what to expect if an employee’s subsidy is appealed. Train field HR staff on what they should do if a subsidy notification is received, where they should send it and who they can contact with questions.

  • Re-educate, Re-communicate and Re-train.

Providing information once is never enough. Benefits leaders should make sure to provide consistent educational content across different communication chan­nels or formats. It may be wise to include information in new employee and open enrollment packets, send out email remind­ers or hang posters with subsidy FAQs in high-traffic areas.

  • Understand the Process.

It’s critical for HR and benefits leaders to understand what’s required of their organi­zation in the subsidy appeal process, plus what the deadlines are to submit documen­tation. There are no deadline extensions or second chances! Employers should decide how they will address subsidy notifications in a timely manner and how that process will work.

  • Appeal for the Right Reason.

Smart HR leaders avoid “always” or “never” when considering an appeal strategy. There are often complexities that require a case-by-case analysis and determination. It pays off to do the research upfront, make an informed decision on the appeal and then take action.

  • Understand the Outcome.

Senior leadership should be prepared for the impact an appealed subsidy may have. This could mean a worried or angry employee, plus potential fines or bad PR for the organization.

  • When Choosing to Appeal, Be Proactive.

It’s optimal for employers to first reach out to the employee and be sure they understand why the organization is choosing to appeal, what may happen and what they can do. Don’t forget that this can be a sensi­tive conversation to have with an employee, and appealing may be in the employee’s best interest.

  • Prepare for Paperwork and Phone Calls.

Filing subsidy appeal paperwork can take 4+ hours of your time to process and 30+ pages of documentation, so benefits teams should be sure to have staff available to focus on these important steps. The person who is listed as the contact on the appeal form should be available to receive calls from the exchange about each individual appeal, so employers should make sure the correct contact information is provided and that the person who is taking the calls is able to handle the sensitive employment and pay information required for a subsidy appeal.

Employees may also want to call a repre­sentative from their organization regarding subsidy appeals, so having a designated contact to answer questions is always helpful. Again, it’s important that the person handling the calls is able to access the sensitive data required to help answer subsidy questions.

While there are indeed many steps and complexities involved in the subsidy man­agement process for your clients, there is no time like the present to help them build a strategy to handle increased notification volumes in 2017. Remember: It’s important to convey that—if managed properly—appealing a subsidy can benefit both your clients and their employees. Appeals can protect employers from unnecessary fines and prevent employees from having to pay back the subsidy amount when they file their tax return.

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