Healthcare reform expert Ed Bray recommends that HR communicate as much as is known at any given time about the impact of reform to employees and top management. With his background in both law and employee benefits, Bray is now director of compliance for Burnham Benefits in Orange County, California.

Here is his counsel, as organizations move beyond Year 2 and closer to 2014, when additional changes take place. Going forward, remember this test: Any plan you offer must be “affordable for employees.” That is, it cannot cost any employee more than 9.5 percent of his or her household income. The government has not yet disclosed how employers can identify individuals’ household income, but it will do so at some point.

Next, remind top management that healthcare reform is not just a benefits issue. Probably in 2014, employers with 200 or more employees must implement automatic enrollment, so that payroll and finance people become involved. In addition, organizations may need to call on outside expertise, for additional W-2 reporting and perhaps financial modeling. Bray reminds us that employers must begin reporting their expenditures on healthcare coverage, per employee, on each employee’s annual W-2. And he stresses the value of employee communications surrounding the W-2 issue; many rumors circulated that the appearance of the amount would mean it was taxable income, which is not the case.

Many employers, Bray reports, are focusing on the wellness side of employee healthcare. He reminds us that of every $1 spent in health care by insurers and employers, 75 percent of it goes to treating chronic conditions. So such illnesses as diabetes, heart disease, and several others should be the focus of wellness programs. Also, adopt a more aggressive approach to wellness, he advises: Try to change employees’ behavior, especially through financial incentives for, as examples, smoking cessation and following fitness goals.

Finally, Bray focuses on the nondiscrimination issue, which many employers are trying to avoid by keeping their plans grandfathered. But the picture there is still fuzzy: Regulations governing nondiscrimination have still not been issued, so HR needs to stand ready to tell top management how they will respond when the regs are available.

Also remember that despite current political furor surrounding healthcare reform, and the many threats to repeal it or get the courts to throw it out, HR needs to go forward as though neither of those will happen. As Bray says, “Keep implementing the known, and stand ready for the uncertain.”