EMPLOYEE BENEFITS WELCOME TO TODAYS WEBINAR! Affordable Care Act (ACA) Employer Reporting Requirements Under IRC Sections 6055 And 6056 Self Funded Health Plans Employee Benefits __
Commercial & Individual Insurance __ Retirement & Investment Services __ Business Consulting www.tpgrp.com 800-722-6339 Portland | Lake Oswego Bellevue | Bend | Bozeman
EMPLOYEE BENEFITS This Presentation Is Intended EMPLOYEE BENEFITS Educate Teams Prompt Dialogue Introduce Resources Help Prioritize ACA Tasks
This Presentation Is Not EMPLOYEE BENEFITS Dont panic This Presentation Is Not EMPLOYEE BENEFITS Legal or tax advice The final word on ACA A political opinion
Before taking any action on the information contained in this presentation, Employers and Plan Sponsors should consult with counsel. Overview EMPLOYEE BENEFITS New tax reporting requirements under the ACA IRC section 6055: reporting of minimum essential coverage IRC section 6056: reporting by applicable large employers under the employer mandate
Reporting to provide the basis for IRS enforcement of: Employer mandate Individual mandate Premium tax credits for Exchange/Marketplace coverage Who Must Report? EMPLOYEE BENEFITS All Applicable Large Employers (ALE) as defined under ACA must comply with the new reporting requirements This includes any employer who employed on average, at least 50
full-time equivalents on business days in the prior calendar year (without regard to your plan year) Six month transition relief rule for 2015 ALE determination Reporting requirements are NOT delayed for mid-size employers even if they qualify for the one year transition relief that delays the employer mandate penalties for one year ALE is based on a control group rules Not sure if you are an ALE? Reach out to your TPG team for assistance
When To Report? EMPLOYEE BENEFITS Individual statements must be provided to applicable individuals by January 31 of following year Provided by the employer for self funded health plans Provided by insurance carrier for fully insured plans Returns must be provided to the IRS by March 31 of following year (February 28 if filing by paper) Electronic filing required for employers filing at least 250 returns
Voluntary reporting for 2014 Mandatory reporting begins for 2015 Penalties of up to $100 per return, with maximum of $1.5 million What Forms Will Be Used? EMPLOYEE BENEFITS 1094-C Transmittal form used to report summary information to the IRS 1094-C is the summary cover sheet that is submitted with individual 1095-C forms
Most employers will complete a single 1094-C form 1095-C Individual statements filed with the IRS and provided to individuals Statements must be completed for Any individual that was an ACA full-time employee during any one calendar month of the year; and Any individual that was covered on the self funded health plan regardless of full time status Who is ACA Full-Time?
EMPLOYEE BENEFITS Each ALE member is independently responsible for identifying its ACA full-time employees for purposes of reporting ACA rules identify two methods for identifying ACA full-time employees The monthly measurement method The look-back measurement period method ALE members should document the decision and establish procedures for the administration of these new rules
Reach out to your TPG team for assistance if you have not yet finalized this step WARNING: Details Ahead EMPLOYEE BENEFITS Form 1094-C EMPLOYEE BENEFITS Reporting Methods EMPLOYEE BENEFITS
General Method Applies to all groups and requires the greatest amount of information collection Simplified Offer Methods Qualifying Offer Method MEC that meets the 60% AV test, offered to the employee and dependents, cost cannot exceed 9.5% of the federal mainland poverty level ($92.38 per month) Does not require the employer to report cost information specific to the employee receiving the qualified offer
95% Transition Relief Does not require the employer to report cost information specific to any employees 98% Offer Method No requirement to identify full-time employees if qualified offer made to 98% of all full-time employees Form 1094-C EMPLOYEE BENEFITS EMPLOYEE BENEFITS
EMPLOYEE BENEFITS EMPLOYEE BENEFITS Form 1095-C EMPLOYEE BENEFITS For self funded employers, form 1095-C serves two purposes:
Employer Mandate (6056): Parts I and II of the form provide information regarding the offer of coverage to any ACA full time employee for purposes of the employer mandate Individual Mandate (6055): Parts I and III of the form provide the required information to both the IRS and any enrolled individual of the self-funded health plan regarding medical coverage for themselves and enrolled family members for purposes of the individual mandate
Complete a 1095-C form any ACA full time employee (that was full time for any one month of the calendar year) and for any employee covered by the self funded plan for any month of the calendar year. Insert Actual Screenshots EMPLOYEE BENEFITS Sarah to work on layout of this section possibly break the reporting section into Part I, II and III based on the format of the 1095 C report.
Exceptions to Section 6055 Reporting (Part III of 1095-C) EMPLOYEE BENEFITS Employers sponsoring insured group health plan (insurer reports instead) HIPAA excepted coverage HRAs that supplement MEC HSAs MEC that supplements a primary plan of same plan sponsor
(or that supplements government-sponsored coverage) Whats Next? EMPLOYEE BENEFITS Make your ALE determination Determine your ACA strategy to limit liability and ensure compliance under the law Select and document your process for identifying ACA full time employees Determine who in your organization will be responsible for
reporting Understand the reporting solution available to you through your payroll and benefits vendors Ensure you are tracking the necessary data that will be required next year Engage your trusted partners for assistance EMPLOYEE BENEFITS Thank you for the opportunity to present to
you today! www.tpgrp.com 800-722-6339 Portland | Lake Oswego Bellevue | Bend | Bozeman
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