What is the New Reporting Requirement?
Massachusetts has resurrected a version of the Health Insurance Disclosure form (HIRD). State law requires every employer in Massachusetts who had six or more employees in any month during the past 12 months preceding the November 30 due date of this form (December 1, 2017 – November 30, 2018) to submit a HIRD. The form collects employer level information only about employer sponsored insurance (ESI) offerings and will be used to inform MassHealth about employers’ ESI offerings. It will also allow more MassHealth members to enroll in premium assistance. It is required regardless of whether the employer offers health insurance to their employees.
How is this Requirement Different from the Old Form?
The former HIRD requirement was repealed in 2014 and consisted of an employer form and an employee form. It also required forms completed and signed by each employee who declined to enroll in the employer sponsored plan or the Section 125 cafeteria plan to pay for health insurance. In contrast, the new disclosure consists of a single employer form which only needs to be completed annually for your company.
When is the HIRD Due and How do I Submit it?
This disclosure will be made available each November 1 of the filing year and will be due by November 30 of the filing year. Employers will log into their account on the MassTaxConnect portal and select the “File health insurance responsibility disclosure link under the account alert. Instructions can be found on the MTC web page, or by contacting the DOR at 617-466-3940. The HIRD form can also be filed by the payroll company, but it is the employer’s responsibility to ensure that it is filed timely.
Are There Any Penalties Associated with this Disclosure?
The HIRD will not be used to impose any new fines or penalties related to the employers’ ESI offerings (or lack thereof). There are no fines or penalties related to your completed HIRD Form.
Massachusetts has released FAQs regarding the HIRD form. For more information on the Massachusetts Health Care individual requirements, visit the Mass.gov Health Care Reform for Individuals website.
About the author
VP, Senior Compliance Manager
Karen Hooper, CEBS, CMS, Fellow, is a Vice President and Senior Compliance Manager working closely with the Lead Benefit Counsel in Newfront's Employee Benefits division. She works closely with internal staff and clients regarding compliance issues, providing information, education and training.
The information provided is of a general nature and an educational resource. It is not intended to provide advice or address the situation of any particular individual or entity. Any recipient shall be responsible for the use to which it puts this document. Newfront shall have no liability for the information provided. While care has been taken to produce this document, Newfront does not warrant, represent or guarantee the completeness, accuracy, adequacy, or fitness with respect to the information contained in this document. The information provided does not reflect new circumstances, or additional regulatory and legal changes. The issues addressed may have legal, financial, and health implications, and we recommend you speak to your legal, financial, and health advisors before acting on any of the information provided.
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