The shoes continue to drop

A week ago today. the Obama Administration’s decision to delay the employer share responsibility penalties for one year — until 2015 — became public.  Today, the IRS formally announced that the IRC §§ 6065 and 6066 reporting provisions will be optional for 2014.  Those provisions require health insurers and self-insuring employers to report to the IRS on health benefits coverage based on the Social Security Numbers of each covered individual, not just enrolled employees and annuitants..

HIPAA provided for the creation of a uniform patient identifier number along wiht uniform provider and health plan identifier numbers.  It strikes the FEHBlog that it’s unfortunate that Congress blocked implementation of the HIPAA Patient Identifier because it would be much easier to report based on that identifier than the Social Security Number which has become the default. It will be a difficult task for insurers to obtain Social Security Numbers on all dependents. A one year delay neither will simplify that task for insurers nor act as the silver bullet that necessarily will permit the IRS to develop a complicated computerized government reporting system.

The Mercer consulting firm made a sensible announcement about the employer mandate delay yesterday

While the announcement that employer shared responsibility penalties will not apply until 2015 was a welcome relief for employers, addressing the fundamental challenges raised by the reform law remains a priority. At the heart of the matter is cost.

In the short term, new fees, plan design changes and the expectation of additional enrollment will add an estimated 2%–3% or more to health plan cost in 2014, even if employers table plans to extend coverage to all employees working 30 or more hours per week. Longer-term, avoiding the excise tax on high-cost plans slated for 2018 remains a daunting challenge. More than a third of employers surveyed by Mercer in May said that they were taking steps in 2014 to help bring down cost by 2018.

The Washington Post reports about the other Affordable Care Act delays that HHS announced last Friday. The delays materially reduce the obligation on the exchanges to verify that individuals signing up for coverage are eligible for taxpayer paid premium and cost sharing subsidies. According to a Forbes contributor the exchanges will be reduced to an honor system for 2014.