The ACA, DOL, EBSA and IRS: “What am I missing…?”

The biggest fear with any new law is what you don’t know or, worse, what you missed. Complying with the Affordable Care Act (PPACA) is the same… With the first period of implementation for groups that are 100 employees or more over, the question now is “did you do it right?”

In any sport, whether it is individual or team oriented, the best in class always review what they did and how they can improve. It’s tough for a business to do this process proactively since typically, customer reaction drives the review process.

I believe it is better to offer a continual review and reflection on what and how to do things better to my clients. The alternative is to create a protected wall around me that simply seals my own fate because I wouldn’t ask myself “What am I missing?”.

Take, for instance, the recent increase in staffing for the enforcement portion of ERISA and the Affordable Care Act. So the enforcement agencies are hiring more staff and/or are asking for more staff…”What am I missing?”. I’m guessing that the compliance factor for employers around these laws are what I call “gapped” – that is, the reality of what documents need to be in place compared to the reality of what documents are in place is large enough to compel the increased labor cost.

I understand I’m projecting business ideas on to the Federal Government, but if the decision process did occur this way, imagine how big the chasm really is for it to be seen by them?

So what is the answer to my question, “What am I missing?”

The answer is that it’s time to review your performance on the documentation end of your Health & Welfare plan. The penalties here aren’t just 15 yards, or a 5 second delay, they are real dollars with real implications on your business, and you don’t get a warning  from these agencies saying “Hey, just wanted you to know that we may be asking for these documents from you in the next couple of weeks”. They just show up or call. So if you’re saying to yourself, “what the hell are these documents?”, give me a call. We’ll found out what you’re missing together.

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