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My testimony: simplify the HIRD Form rules
George L. Chimento
September 10, 2007
1. The Division of Health Care, Finance, and Policy (the "Division") held
public hearings on September 5. On behalf of clients, I testified and offered
comments urging simplification. My written comments are at this link.
If you are a Massachusetts employer, you hopefully are aware by now that the
Division issued emergency regulations on June 20 and published an initial HIRD
(Health Insurance Responsibility Disclosure) Form.
Employees who decline health insurance coverage, and part-time employees who
reject use of employer cafeteria plans to pay the full cost of their coverage, must
answer 5 questions and sign the forms. Employers must obtain signatures and
retain forms for three years.
The deadline to get employee signatures, in most cases, is September 30. If you
do not know what a HIRD Form looks like, here is a link to earlier articles written
on July 14, 2007 and August 22, 2007. Within them are copies of the Employee
HIRD Forms (in English, Spanish, and Portuguese), and a link to the emergency
regulations.
2. Why bother with testifying ?
I would like to see more access to health care. However, it is not good policy for
Massachusetts to overburden employers. They are already regulated to the hilt by
the federal government, and most Massachusetts employers already provide
health insurance.
Those of you with human resource responsibilities know that the current version of
these HIRD forms is too complicated for the average (and above-average)
employee. So I took advantage of the public hearing to put on record my concerns,
and suggestions. I hope the Division listens.
I do note that the Commissioner of the Division (Sarah Iselin) and her staff seem
genuinely concerned to do the job correctly. I'm somewhat optimistic that they will
respond with a simpler version of the Employee HIRD Form and procedures.
________________________________________________________________
This article is provided as a courtesy and may not be relied upon as legal advice,
or to avoid taxes and penalties. Distribution to promote, market, or recommend
any arrangement or investment to avoid or evade taxes, including penalties, is
expressly forbidden. Any communication with the author as to its contents, does
not, of itself, create a lawyer-client relationship. Under the ethical rules applicable
to lawyers in some jurisdictions, this may be considered advertising.
return to theworkplace.biz
My testimony: simplify the HIRD Form rules
George L. Chimento
September 10, 2007
1. The Division of Health Care, Finance, and Policy (the "Division") held
public hearings on September 5. On behalf of clients, I testified and offered
comments urging simplification. My written comments are at this link.
If you are a Massachusetts employer, you hopefully are aware by now that the
Division issued emergency regulations on June 20 and published an initial HIRD
(Health Insurance Responsibility Disclosure) Form.
Employees who decline health insurance coverage, and part-time employees who
reject use of employer cafeteria plans to pay the full cost of their coverage, must
answer 5 questions and sign the forms. Employers must obtain signatures and
retain forms for three years.
The deadline to get employee signatures, in most cases, is September 30. If you
do not know what a HIRD Form looks like, here is a link to earlier articles written
on July 14, 2007 and August 22, 2007. Within them are copies of the Employee
HIRD Forms (in English, Spanish, and Portuguese), and a link to the emergency
regulations.
2. Why bother with testifying ?
I would like to see more access to health care. However, it is not good policy for
Massachusetts to overburden employers. They are already regulated to the hilt by
the federal government, and most Massachusetts employers already provide
health insurance.
Those of you with human resource responsibilities know that the current version of
these HIRD forms is too complicated for the average (and above-average)
employee. So I took advantage of the public hearing to put on record my concerns,
and suggestions. I hope the Division listens.
I do note that the Commissioner of the Division (Sarah Iselin) and her staff seem
genuinely concerned to do the job correctly. I'm somewhat optimistic that they will
respond with a simpler version of the Employee HIRD Form and procedures.
________________________________________________________________
This article is provided as a courtesy and may not be relied upon as legal advice,
or to avoid taxes and penalties. Distribution to promote, market, or recommend
any arrangement or investment to avoid or evade taxes, including penalties, is
expressly forbidden. Any communication with the author as to its contents, does
not, of itself, create a lawyer-client relationship. Under the ethical rules applicable
to lawyers in some jurisdictions, this may be considered advertising.
return to theworkplace.biz
| GOOD NEWS. THE DIVISION DID SIMPLIFY THE HIRD FORM AFTER THAT HEARING. HERE IS AN UPDATE ON THE NEW FORM. |