As part of the Massachusetts health care reform law, employers employing six or more employees in the Commonwealth are required to make an Employer Medical Assistance Contribution (EMAC) to help fund health coverage for the uninsured. Further, these employers are required to annually file the Health Insurance Responsibility Disclosure (HIRD) form (see Massachusetts: Employer Medical Assistance Contribution Updates and New Annual Reporting Obligation, Benefit Beat, February 7, 2018).
The Massachusetts Department of Revenue just released a set of FAQs relating to the HIRD reporting form. The purpose of this form is to assist MassHealth in identifying those individuals with access to employer sponsored coverage who may be eligible for premium assistance.
The form is required to be filed by any employer employing 6 or more employees in any month during the past 12 months preceding November 30th of the reporting year, without regard to whether the employer offers health coverage. Individuals included in quarterly wage reports to the Department of Unemployment Assistance are deemed to be employees.
This form can only be filed online through the MassTaxConnect portal. Reporting entities must log into the portal in order to obtain the HIRD form. The type of information requested for completing this form relates to employer-provided health coverage; specifically, insurance-related information, such as premium cost, types of benefits offered, cost sharing details and eligibility. The form does not collect individually identifiable information.
This report is due annually by November 30th of the reporting year, beginning in 2018. While third party payroll vendors can assist in completing the form, it is ultimately the employer’s responsibility. The form is not used to assess penalties against the employer for failure to offer health coverage. A penalty for failure to complete the HIRD form, though, could be imposed.