November 16, 2018
Beginning in 2018, employers with six or more employees in Massachusetts are required to submit a Health Insurance Responsibility Disclosure (HIRD) form to the Massachusetts Department of Revenue. The HIRD form collects information that will assist in identifying individuals who may be eligible for the MassHealth Premium Assistance Program. The 2018 deadline for submitting the HIRD form is November 30, 2018.
HIRD reporting is administered by the Department of Revenue through the MassTaxConnect website. The MassTaxConnect website is where employer-taxpayers register to file returns, forms, and make tax payments. To file a HIRD form, an employer would login to its MassTaxConnect account and select the “File health insurance responsibility disclosure” hyperlink under the account alerts.
The HIRD form may be filed either by an employer or its payroll company. Employers should contact their payroll company to determine who will be submitting the form. Even if a payroll company does submit the form, it is the employer’s responsibility to ensure that the HIRD form is timely filed.
Guidance released by the Massachusetts Department of Revenue about the HIRD reporting requirement is available here: https://www.mass.gov/files/documents/2018/10/24/health-insurance-responsibility-disclosure-FAQ.pdf
While there is no guidance on how employers that contribute to multiemployer plans would complete the form, FAQ 16 does recognize that an employer’s health insurance offering may vary based on union affiliation. The FAQ indicates that employers should follow the instructions on the HIRD form and enter all applicable information as they relate to health insurance offerings.
For questions regarding the HIRD reporting requirement, please contact Segal. You may also contact the Department of Revenue’s customer service center at 617-466-3940 and choose the option to speak with a HIRD representative.
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