While details of their notification and reporting obligations regarding the public insurance exchanges established under the health care reform law remain unsettled, employers shouldn't wait to review their readiness to meet those requirements, experts say.

Under the U.S. Patient Protection and Affordable Care Act, employers sponsoring group health benefits will be required to notify employees and new hires of the availability of coverage through public exchanges operated by individual states or the federal government. The notifications must include a description of services provided by the exchanges, as well as instructions for contacting the exchanges.

Employees also must be informed they may be eligible for federal premium subsidies and tax credits for coverage bought through an exchange, if their employer's group health plan does not meet minimum essential care requirements; if the employer covers less than 60% of the total cost of benefits; or if employees' premium contributions exceed 9.5% of their household income.

Originally, the notification requirements had been scheduled to take effect on March 1 of this year. However, the U.S. Department of Health and Human Services has yet to issue guidance relative to the recommended wording of the notification materials, as well as the methods by which employers may be required to distribute that information.

On Jan. 23, federal officials announced that the notification requirement’s effective date is postponed indefinitely until regulations are issued and “become applicable.”

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“It certainly would have been nice to have gotten it by now, if not before the end of the fall,” said Mark Holloway, senior vice president and co-director of compliance services for Kansas City, Mo.-based Lockton Cos. L.L.C. “That way, employers could have included the notification in their open-enrollment communications. Now that we're past that point, I would guess that HHS is going to move that March 1 deadline further out into the year.”

Additionally, beginning in 2015, self-insured employers will be required to report details of their group health plans to the Internal Revenue Service, including the identities of all individuals insured under the plan, the dates for which those individuals are covered, and any contributions made to the total cost of benefits provided. Employers also must specify whether the coverage they offer is a qualified health plan offered through a public exchange, as well as any federal premium subsidies paid to plan members.

Coupled with the IRS reporting requirement, employers must provide written notification to each covered individual named in their reports outlining the information provided to the government.

Those reporting and notification requirements are scheduled to take effect Jan. 31, 2015, and will apply to coverage provided on or before Jan. 1, 2014. However, questions remain as to how exactly employers should determine individual plan members' coverage effective dates and how to handle the coordination of information with third-party administrators. Employers also have raised the issue of potential redundancies with other reporting requirements under the health care reform law.

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The IRS has said it plans to issue further guidance to address those concerns, but it has not indicated when that guidance will be released.

In the meantime, experts said employers should carefully examine their current benefits communication strategies to identify any underserved segments within their covered group, as well as examine the potential costs associated with layering additional print and electronic distribution models.

“Regardless of how much of this plays out, there will be a cost associated with distributing these notifications to employees, and employers need to be developing a game plan to deal with that eventuality,” said Jon Trevisan, the Boston-based director of placement at Willis North America Inc.'s national human capital practice.

After the government does issue its recommendations regarding the content of the required notifications, experts said employers should confer with their in-house legal counsel, benefits management team and divisional managers to tailor the message in order to maximize employees' comprehension of the materials.

“You need to be prepared to personalize those communications at some level,” said Eric Grossman, a Norwalk, Conn.-based senior partner at Mercer L.L.C. “Probably not necessarily at the individual level but certainly at the group level, you will want to fit your communications to your group's needs and preferences.”