Have you HIRD? The Health Insurance Responsibility Disclosure

Have you filed your Health Insurance Responsibility Disclosure form yet?  Time is running out, it must be completed by November 30, 2018.   Some of you will remember the old HIRD form from 2006.  That was a nightmare to fill out it and it required an employee form and an employer form for every employee.   The good news is this 2018 version is nothing like that and, for the most part, is easy to fill out once you gather the necessary information.

The Department of Revenue has put out a question & answer document to help employers, here is the link: https://www.mass.gov/files/documents/2018/10/24/health-insurance-responsibility-disclosure-FAQ.pdf.

Most employers will be able to answer these questions without a problem. Below are some of the questions that may slow you down:

  • Does employer offer different health plan benefits/rates for health plan benefits according to employment based categories for different groups of employees?

In most cases, the answer to this is NO and should be NO.  If you offer a particular plan to only a certain class (i.e. management or owners) of employees, you will need to answer YES and select the appropriate boxes below this question.

  • Name of the health insurer and name of the health plan.

You will need the name of your Health Insurance Carrier as well as the full name of the plan(s) you offer.  You can find this information on your most recent Summary of Benefits for each plan.

  • Do the benefits provided under the health insurance plan satisfy the minimum creditable coverage requirements?

In most cases, your answer will be YES.  You can also find this in the Summary of Benefits for your plan.  There will be a statement included that states it meets the minimum creditable coverage.

Levels of Coverage

This section will require the most in-depth information.  You will need payroll info as well as the Summary of Benefits for your plans.

Q. Which levels of coverage are offered by this plan?

If you offer all 4 tiers (Individual, Employee + 1, Employee + Children, Family), you will need to enter 4 all four levels.  You will have to complete this for each plan you offer.

Example:

Plan 1    Individual

Plan’s Total Monthly Cost                             $ xxx.xx    Monthly cost of plan paid to health                                                                                                                              carrier

Employee’s Monthly Contribution           $ xxx.xx    Monthly premium employee cost

In-Network Annual Deductible                 $ xxxx.xx   Found on the Summary of Benefits

Annual Out of Pocket Max Expense         $ xxxx.xx   Found on the Summary of Benefits

Plan 1    Employee Plus One                                       Answer all 4 questions

Plan 1    Employee Plus Children                               Answer all 4 questions

Plan 1    Family                                                               Answer all 4 questions

Plan 2    Individual                                                        Answer all 4 questions

Plan 2    Employee Plus One                                        Answer all 4 questions

Plan 2    Employee Plus Children                                Answer all 4 questions

Plan 2    Family                                                                Answer all 4 questions

 

You might ask why the state needs or wants this information.   This is right out of the DOR’s published FAQ:

MassHealth is identifying its members with access to qualifying insurance who may be eligible for the MassHealth Premium Assistance Program.

The state is attempting to find employees that are on MassHealth, but working for a company that offers health insurance.  The state could move some of these employees to the MassHealth Premium Assistance Program. This is very bad for employers as you will now be required to pay your employer share of the health insurance which, in most cases, would be five to ten times more than the EMCA charge.  This could make the EMCA look like small change.

If you have questions about the HIRD form or would like more information you can reach out to Rich Volkmann at [email protected].