Equifax Workforce Solutions’ 2017 client forum was themed “Expanding Horizons”, and here I take a quick look at three areas in which Equifax is expanding its HR solutions. 

Expanding Verifications Business

Equifax’s verification services business is expanding beyond the U.S., launching first in Canada, followed by the U.K., and then Australia. Currently, the company’s U.S. income and employment verifications are sourced from The Work Number, and through its multi-country expansion plan, Equifax will have the largest global database of income and employment information.

Workforce Analytics

Equifax is also using big data to provide critical workforce insights, such as tenure and turnover of new hires. This information can help organizations mitigate costs associated with new hires, especially when coupled with Equifax’s compliance center.  

ACA Subsidy Management

It’s impossible to predict the possible scenarios of ACA under the new U.S. government administration. While change is certain, the employer provision, and more importantly penalties, remain intact, so compliance is paramount.

To recap, the employer mandates require organizations with 50 or more full-time employees (i.e. employees working on average at least 30 hours per week) to offer health coverage that provides “minimum value” and is “affordable” to at least 95% of their FTEs, or else they are liable to a penalty. 2017 penalties are either $2,260 per FTE or $3,390 per FTE where the employee is not offered coverage.

In addition, employers must comply with 6055/6056 reporting requirements. Failure to file or filing incorrect statements will result in additional penalties of $260 per form, capped at $3.1m.

To facilitate legislation, many suppliers have launched offerings around eligibility tracking and IRS form fulfillment, including 1095C distribution as well as 6055/6056 reporting. However, the subsidy provision also remains in place, and will likely present the greatest issues for organizations.

Last year, Equifax expanded its ACA offering by launching a subsidy management service to assist employers as they receive subsidy notifications for failure to comply with the ACA employer mandate, and subsequent appeals process. The offering includes preliminary case analysis, consultation, end-to-end case management, and outcome-based reporting.

In 2016, the Centers for Medicare & Medicaid Services (CMS) sent out ~450k subsidy notifications, and Equifax received ~1.7k and filed ~580 appeals on behalf of ~150 clients. Approximately 62% of the appeals yielded a favorable determination.  

To date, there is no guidance about the agenda for 2017 regarding subsidy notifications. However, organizations need to understand the penalty exposure associated with subsidies as well as the challenges of appealing subsidy notices.

The 2017 penalty under 4980(a) is $188.33 per month per employee for all employees, and the penalty under 4980(b) is $282.50 per month per subsidized employee. Therefore, non-compliance can result in a massive penalty for some organizations.

It’s important to note that an appeal will not be necessary for every subsidy notice received, but employers should be ready to appeal if they did offer coverage to their full-time employees. Employers will have 90 days to file their appeal. The biggest challenge for organizations during the appeals process will be to gather all the documents that support the appeal in time. On average, each appeal response is between 30 and 80 pages, and consumes several hours, which is why services like Equifax’s are very valuable, saving time for HR and benefits personnel to focus on more strategic activities.