MA Implements New Requirement for “HIRD” Form

By Richard S. Loftus   November 8, 2018

WHAT’S NEW?

Starting this November, the Commonwealth of Massachusetts will implement a new requirement for employers with six or more employees to file a Health Insurance Responsibility Disclosure (“HIRD”) form annually. The HIRD form is intended to collect employer-level information about the particular health insurance that each employer offers to its employees. The Commonwealth seeks this information in order to help it identify individuals who have access to employer-provided health insurance and who may be eligible for MassHealth’s Premium Assistance Program.

The HIRD form seeks information about employer-sponsored health insurance and should be completed through the MassTaxConnect web portal. Employers might recall that from 2006-2014, they were required to complete a HIRD form which employees also had to fill out. This HIRD iteration does not contain that requirement, and only employers must complete the HIRD form.

WHAT IT MEANS FOR EMPLOYERS

The HIRD form is intended to be completed using information readily available to employers, typically through their Human Resources departments and often contained in the “summary of benefits” prepared by the health plan(s) the employer currently offers. The HIRD form does not ask for any personally identifiable information about any employees and seeks only high-level information about the employer’s health plan offerings. The form will not be used to assess any penalties to employers based on their health plan offerings.

Employers will need to complete the HIRD form once annually by November 30 of each year through the MassTaxConnect web portal. As this is the first year for the requirement, there will be no penalty for failing to file by November 30.

FOR MORE INFO/COMPLIANCE ASSISTANCE
  • The Commonwealth has issued a FAQs page about the HIRD form here.
  • You can also get more information about the Premium Assistance Program here.
  • Please contact Richard S. Loftus or any other member of HRW’s employment law team for additional information or compliance assistance.

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