ACA Compliance Begins with Clean Member Records

 In Data, Health

Accurate and secure maintenance of thousands of member records (along with those of their dependents) is a taxing and necessary function of modern fund operations. The benefits of clean records are many: better service, accurate reporting, and the confidence that compliance with the new ACA mandates can be achieved. To avoid a mad dash to update “member data,” we recommend constant vigilance on the task of participant data integrity. This may prove to be one of the most cost-efficient initiatives in the fund office.

The Affordable Care Act (ACA) mandates certain monthly reporting requirements (for multiemployer plans that offer health benefits) that now come with harsher penalties for inaccurately reporting information (penalties can be more than double that of former healthcare fines! ¹. For instance, if a person’s social security number is missing, or the year that they initially gained health eligibility was accidentally mixed up with the year the member was married, there is a very real possibility that the fund will be responsible for paying the penalty if the information is not corrected within an acceptable time period. Therefore, it is high time to assess the effectiveness of your organization’s upkeep of the countless member records for which you are responsible.

Approaching member data maintenance with careful organization and a capable team equipped with simple tools will help alleviate the potential stress that arises from inaccurate or incomplete information. This may sound trivial and tedious, but being organized is one of the most underrated facets of record keeping. Everything – from the number of staff that touch member records to the storage of personal data that may date back decades – deserves personal-infoscrutiny and must be logically documented and stored in a trusted location. However, organization alone does not determine the accuracy of records; people do. Member record maintenance is a mission-critical aspect of your fund operations and it is imperative that you have a trained team, whose primary mission is to maintain a high level of data integrity on behalf of all members. These are the people who can recognize and correct errors before they cause problems (“hey – that marriage date doesn’t look right, we better verify it before it gets entered into the system”). These are also the people who will ensure that downstream processes and communications run without errors – think of the time and money saved if a fund office staff were able to easily retrieve and trust the accuracy of the afore-mentioned missing SSN, come ACA reporting time.

From our experience, the time it takes to track down and update participant information – what we like to call “member data” – can add a wrinkle to the busy activity within daily fund operations. This issue can be avoided if the time and care is taken to properly maintain the integrity of member data as it is collected. It all starts with an organized process and having the right people.


¹IRS Information Reporting by Applicable Large Employers-Information Reporting Penalties

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