The Employers for Flexibility in Health Care (E-FLEX) Coalition filed a comment letter yesterday on the proposed employer reporting requirements under the Affordable Care Act (ACA), which will be used to verify the individual and employer mandates. The E-FLEX Coalition, chaired by the Retail Industry Leaders Association (RILA), has engaged in constructive conversations with the Department of Treasury and IRS about streamlining numerous ACA employer requirements, including making these data collection rules for individuals and businesses more flexible.
“Streamlining the reporting process would not only help employers comply with these requirements, but more importantly may help prevent individuals and their families from being told they now have to pay for an Exchange coverage tax credit they were wrongly given,” said Christine Pollack, chair of the Coalition and vice president of government affairs at RILA.
In the letter, the Coalition, “urges the Administration to take a measured approach to information reporting that strikes a balance between the administrative burden of new employer reporting requirements and the data that actually will be needed to administer the employer and individual shared responsibility provisions and premium assistance tax credits.”
The letter references the Congressional Budget Office’s (CBO) May 2013 report, “Estimate of the Affordable Care Act’s Effect on Insurance Coverage,” which estimated that more than 155 million Americans will continue to receive their coverage through employer-sponsored health plans through 2023 (the last year included in the CBO’s projection). The CBO also projected that no more than 500,000 individuals in 2014, 2015 and 2016 will enroll in Exchanges as a result of an unaffordable offer of employer-sponsored coverage, growing to 1 million individuals from 2017 to 2023.
Requiring employers to report to the IRS detailed information for the more than 155 million Americans is extremely burdensome. “The E-FLEX Coalition believes a less expansive approach to information reporting can achieve the same ends with fewer burdens to the IRS and employers who voluntarily provide health coverage without giving rise to any adverse effects for individuals,” the group states in the letter.
The Coalition letter also stresses:
- Utilizing a certification method is a reasonable approach that could be used as the basis for a simplified reporting process that could benefit employers of all sizes and structures.
- The collection of data on every employee and their dependents covered in an employer-sponsored plan would not intrinsically improve the administration of the ACA’s premium tax credits and employer tax penalties.
The Employers for Flexibility in Health Care (E-Flex) Coalition is a group of leading trade associations and businesses in the retail, restaurant, hospitality, construction, temporary staffing, and other service-related industries, as well as employer-sponsored plans insuring millions of American workers.
The E-Flex Coalition represents employers who create millions of jobs each year, employ a significant workforce in the U.S., offer flexible working environments for employees, and are a leading contributor to the nation’s economic job recovery. Members of the E-Flex Coalition are dedicated to the common goal of creating solutions for both large and small employers and are working to help ensure that employer-sponsored coverage – the backbone of the U.S. health care system – remains a competitive and affordable option for employers and for employees whether full-time, part-time, temporary, or seasonal workers.