Massachusetts employers with six or more employees must file a Health Insurance Responsibility Disclosure (HIRD) form with the state Department of Revenue (DOR) by November 30.
The HIRD form, required by a 2017 state law that took effect in 2018, collects employer-level information about employer-sponsored insurance (ESI) offerings. The HIRD reporting, administered by MassHealth and the DOR, is designed to help MassHealth identify its members with access to qualifying ESI who may be eligible for the MassHealth Premium Assistance Program.
Any employer that has or had six or more employees in any month out of the past 12 preceding the November 30 due date (that is, since December 2017) must submit the HIRD form via the MassTaxConnect Web portal. These employers must submit the form even if they do not actually offer health coverage. An employer may use a payroll company to file the HIRD, but is the employer’s responsibility to make sure the form is filed on time, according to DOR guidance.
The HIRD form collects only employer-level information about health plan offerings, not any personal information about employees. Employers are not required to report on flexible spending arrangements, health reimbursement arrangements, or health savings accounts.
The DOR expects that an employer’s human resources and/or benefits department should have access to all of the information necessary to complete the HIRD form. Some of it will be in the health plan’s benefits summary, such as the monthly employee contribution, in-network deductible, and in-network out-of-pocket maximum. Other information will likely come from the employer’s policies, like the hours worked per week to qualify for health coverage and any employment-based categories that affect eligibility.