New York New Hire Reporting Requirements

[Guest ERISAQUEEN]

Effective July 15, 2011, as part of New York's new hire reporting requirements, New York employers must report whether health insurance benefits are available to dependents, and if so the date the employee qualifies for benefits. Multi-state employers may continue reporting to their designated state as long as such reporting includes New York's required information.

While the new law allows for multi-state employers to continue reporting to their designated state, I am finding that states are not modifying their reporting format to accomodate this new information.

My question: How are other multi-state employers reporting this information?

One solution that I have is for multi-state employers to report information for New York employees directly to New York using its on-line reporting system.

Any comments or suggestions are much appreciated.

[Peter Gulia]

And has anyone yet taken the position that ERISA preempts the New York law that otherwise would require this information?