1. ACA:COMPLIANCECHECKLIST
Postlethwaite and Netterville, A Professional Accounting Corporation
AUDIT & ACCOUNTING + CONSULTING + TAX SERVICES + TECHNOLOGY www.PNCPA.com
1. Do you offer health insurance?
+ If yes, is your plan grandfathered and if so, do you the documentation to support that?
+ If yes, and your plan is not grandfathered, have you discussed the various new coverage
requirements with your agent?
+ If no, have you analyzed whether you are a small or large employer for purposes of the pay or play
mandate?
Have you considered related entities in this determination?
Have you considered leased or staffing agency employees?
Have you considered your independent contractors?
Have you considered prevailing wage employees?
Have you considered the six months transitional rule for 2013?
If you have or if you are considering reducing current employee hours below 30, have you
also considered the impact of ERISA §510?
2. Whether you offer insurance or not are you ready to provide the model DOL notice regarding the availability
of insurance on the marketplace?
3. Do you hire variable hour or seasonal employees? Variable hour employees are those that have no set work
schedule and seasonal employees are those that work 120 days or less.
+ If yes, have you established an initial measurement period?
+ Have you established an administrative period?
+ Have you established a standard measurement and stability period?
+ Have you established a break in service rule? If yes, have you also considered the rule of parity?
+ Do your measurement periods comply with the 13 month rule?
4. If you sponsor an Employee Assistance Program have you provided a Summary of Benefits and Coverage to
your employees for this plan?
5. Do you sponsor a standalone Health Reimbursement Arrangement? If yes, have you amended the plan to
provide only HIPAA excepted benefits after January 1, 2014?
6. Do you sponsor a Health Reimbursement Arrangement that is integrated with health insurance? If yes, are
you ready to file and pay the Comparative Effectiveness Research see on July 31, 2014 and for the three
successive years thereafter?
7. Do you sponsor an uninsured retiree health plan? If so, have you considered whether the plan is subject to the
Comparative Effectiveness Research fee?
8. Do you sponsor a cafeteria plan?
+ If you have a fiscal year plan and you are a large employer, have you considered amending the plan to
allow those employees who qualify for subsidies to make a change of status election in order to
participate on the individual exchange?
+ Have you amended your cafeteria plan to preclude the purchase of individual policies from the
exchange on a pretax basis?
+ SHOP coverage may still be purchased on a pretax basis through a cafeteria plan.
+ Does your cafeteria plan have a health FSA? If so, has the plan been amended to reflect the $2,500
limit?