Don’t Forget that ACA Affects Your Agency Operations

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Karen Utterback By Karen Utterback 
Former Vice President, Product Marketing and Strategy, McKesson (Retired)

ACA Employer Mandates Impact Home HealthHome health and hospice agencies have been focusing on how the Affordable Care Act affects their reimbursements and how they can participate in new care models. What may have been lost in the shuffle is how ACA will impact agencies as employers, says Mark Sharp, CPA, partner at BKD, LLP.

Sharp outlines five steps that agency executives should take to plan for ACA employer mandates:

  • Educate yourself on the requirements
  • Conduct a compliance review with an ERISA attorney
  • Conduct a financial analysis with your CPA or insurance consultant
  • Gather an advisory team to plan strategy
  • Put your plan into action

Current staffing levels will determine whether you are subject to the “pay or play” rules that now begin in January 2015. Sharp says that if your agency has 50 or more full-time employees, then you must provide a minimum level of insurance for full-time workers or pay a penalty. If your agency has fewer than 50 full-time employees, then you have to look at your full-time equivalents for part-time employees also as calculated in the regulations.

Companies with subsidiaries, such as hospital-owned hospice and home health agencies, have to aggregate numbers with the parent company, according to Sharp. Agencies can use two methods to determine whether an employee is full time and should be offered insurance: either counting hours on a monthly basis or looking back at the average hours worked by employees over a period of time and creating a “stability period.” Sharp says the latter method is better suited to seasonal or variable hour employees.

He says that additional rules stipulate how “minimum essential coverage” is calculated, who is eligible, minimum deductibles and more. That is why Sharp advises agencies to seek outside consultants who are well-versed in ERISA and insurance benefits to make sure that any plan an agency adopts meets the standards.

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