employer reporting under the aca - efgmbenefits.com reporting... · section 6055 reporting...
TRANSCRIPT
Employer Reporting under the ACA
Suzanne Spradley, SVP, Sr. Counsel, Legal & Compliance Chase Cannon, VP, Counsel, Legal and Compliance
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Employer Mandate Basics
Applicable large employers must offer minimum essential coverage (MEC) that is affordable and meets minimum value standards to FTEs and their dependent children up to age 26.
Employer Size
Effective for plans beginning in 2015
2016 plan years and beyond
50 – 99 FTEs *including FT equivalents
Possible delay if employer: • Maintains workforce size • Maintains coverage
1. 95% of dollar amount or 2. Same % of contribution
• Certifies on Form 6056
Employer must offer coverage to 95% of FTEs
*not including FT equivalents
100+ FTEs *including FT equivalents
Employer must offer coverage to 70% of FTEs
*not including FT equivalents
Employer must offer coverage to 95% of FTEs
*not including FT equivalents
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Employer Mandate - Penalty B
Minimum Value – The plan must pay on average at least 60% of allowable costs for all covered services on an aggregate basis.
Affordable - The employee’s required deduction for single only coverage for the least expensive plan the employer offers that meets the 60% Minimum Value threshold cannot exceed 9.5% of employee’s wages.
There are three affordability safe harbors
Certified on Form 1095-C
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Penalty Amounts
Penalty A
$2,000 times each full-time employee Minus the first 30 employees (80 in 2015)
Penalty B
$3,000 times each full-time employee who receives a premium tax credit
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Section 6055/6056 Employer Reporting
Penalty Assessment: Reporting Cycle
Individual Goes to Exchange Exchange to HHS Exchange to Employer
HHS to IRS IRS collects 1040 IRS collects ER Report
IRS IRS to Individual IRS to Employer
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Employer Reporting Overview
6055 Enforce individual
mandate
Insurers
Self-insured Plans
Forms 1094-B, 1095-B filed by
insurers and SG self-insured plans
6056 Enforce employer
mandate
Applicable large employers
Members of a ALE control group
Forms 1094-C and 1095-C filed by
employers and LG self-insured plans
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6055 Reporting
Section 6055 Reporting
Reporting by any entity that provides:
minimum essential coverage (MEC)
to individuals enrolled during a calendar year
Information is used for purposes of the individual mandate
Type of Plan Who Files Report Which Forms
Insured Plan Insurance Carrier Forms 1094-B & 1095-B
Self-Insured Plan 1 – 49 FTEs
Employer Forms 1094-B & 1095-B
Self Insured Plan 50+ FTEs* Or member of control group that is 50+ FTEs
Employer Form 1095-C, Part III
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6056 Reporting
Section 6056
Reporting by:
an applicable large employer (ALE) or member of a control group that is an ALE
on group health coverage whether or not offered to
full-time employees
whether or not full-time employee is enrolled
Information is used to determine:
employer’s compliance with employer mandate
Individual’s qualification for premium tax credit
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Question: Employer Mandate Delay for Employers with 50-99 FTEs
Question: What if my company qualifies for transition relief from the employer mandate until 2016. Do I still need to report for purposes of 2015?
Answer: The transition relief does not delay the 2015 employer reporting obligations. You must submit Forms 1095-B and 1095-C covering 2015 data, which are due in 2016.
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Which Forms must be filed for 6056 ALE reporting?
Form 1094-C
Transmittal Form Generally one per FEIN Control Group information Compliance with Penalty A threshold
Form 1095-C
Employee Statement One for each FTE Compliance with Penalty B affordability threshold Information on coverage offered / not offered If self-insured, information on individuals enrolled
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When are the Forms Due?
To Employees
Jan 31st (or Feb. 1 in 2016)
To IRS
Feb. 28 if paper filing Mar. 31 if electronic filing
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Form 1095-C: Delivery to Employee
Mail Paper Forms to Last Known Address
• Could be combined with Form W-2 mailing
Electronic Delivery
• Must obtain affirmative consent
Hand Delivery
• Signature of receipt recommended
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Question: Filing Electronically
Question: How do we file electronically?
Answer: The Affordable Care Act Information Returns (AIR) may be electronically filed
by completing an e-services registration on: https://la1.www4.irs.gov/e- services/Registration/Reg_Online/Reg_RegisterUserForm
The IRS will issue registration confirmation code through U.S. Postal Service
Use the confirmation code to login within 28 days
May contract with a vendor on your behalf
Publication 5165: http://www.irs.gov/PUP/for_taxpros/software_developers/information_returns/ Draft_Pub_5165_04_2015.pdf
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Data Required for Reporting
ALE Member Information
Address, EIN, etc. # of FTEs # of all employees
Controlled Group Information
Names of CG members EINs of CG members # of FTEs for each member
Employee Information
Names, address, etc. SSNs of EE and dependents Months as FTE Months in waiting period / initial measurement period
Offer of Coverage Information
Minimum value? Affordable? Cost of self-only tier Offer made to spouse / child MEC offered to 70%/95% of FTEs?
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Question: Payroll Vendor Assistance on Reporting
Question: Will my payroll company handle this for me? If not, who is responsible for filling out these forms?
Answer: The employer is responsible for filling out Form 1094-C and 1095-C if the employer is an applicable large employer (ALE) or a member of a control group that is an ALE. Many payroll companies have a employer reporting module that you can purchase as do benefit administration companies. There are also stand-alone vendors.
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Question: Consequences for Noncompliance
Question: What if I don’t comply with Section 6056?
Answer: • Failure to comply with Section 6056 reporting may result in:
• $250 per failure (per return) • Intentional disregard = $500 per failure • For 2015 only - no penalty for good faith effort
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Section 6056 Reporting: Getting into the details
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Form 1094-C Transmittal
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NOTICE
Notice
These 2015 forms and instructions are draft versions only and should not be relied upon for filing. The IRS may make changes prior to releasing final 2015 versions.
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Form 1094-C Overview
Form 1094-C is cover letter for 1095-C employee statements
Identifies employer and provides information about affiliates (control group members)
A third party or affiliate may assist an ALE member with reporting:
However, the ALE member cannot transfer its potential liability for failure to report.
Except, a government entity may be designated to file for another governmental unit (“Designated Government Entity (DGE)”).
DGE must file a separate Form 1094-C for each ALE member for which the DGE is reporting.
On lines 9-13 of Form 1094-C, Part I, the DGE would report its name, address and EIN and on lines 1-8 the name, address, and EIN of the ALE member for which it is reporting.
Answers the question of whether the employer met Penalty A threshold (70% / 95% of FTEs offered coverage)
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DRAFT AS O Jun 16, 2015
DO NOT FIL
Draft Form 1094-C Part I - Employer Information
Form1094-C Department of the Treasury Internal Revenue Service
Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
▶ Information about Form 1094-C and its separate instructions is at www.irs.gov/f1094c. FCORRECTED
120116
OMB No. 1545-2251
2015
Part I Applicable Large Employer Member (ALE Memb er) 1 Name of ALE Member (Employer) 2 Employer identification number (EIN)
3 Street address (including room or suite no.)
DGE
4 City or town 5 State or province 6 Country and ZIP or foreign postal code
7 Name of person to contact 8 Contact telephone number
9 Name of Designated Government Entity (only if applicable) 10 Employer identification number (EIN)
11 Street address (including room or suite no.)
12 City or town 13 State or province 14 Country and ZIP or foreign postal code
For Official Use Only
15 Name of person to contact 16 Contact telephone number
17 Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18 Total number of Forms 1095-C submitted with this transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
19 Is this the authoritative transmittal for this ALE Member? If “Yes,” check the box and continue. If “No,” see instructions . . . . . . . . . . . . . . . .
20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
21 Is ALE Member a member of an Aggregated ALE Group? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If “No,” do not complete Part IV.
22 Certifications of Eligibility (select all that apply):
A. Qualifying Offer Method B. Qualifying Offer Method Transition Relief C. Section 4980H Transition Relief D. 98% Offer Method
Under penalties of perjury, I declare that I have examined this return and accompanying documents, and to the best of my knowledge and belief, they are true, correct, and complete.
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▲
▲
Signature Title Date
For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61571A Form 1094-C (2015)
▲
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Example
Facts: Joe Smith owns a restaurant with 70 full-time employees (including full-time equivalents) and a dry cleaner with 10 full-time employees.
Question: Can the companies combine information into one Form 1094-C ?
Answer: No. Members of a controlled group have separate reporting responsibilities and cannot combine their information into one Form. Each member must file a separate Form 1094-C.
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▲
▲
Draft Form 1094-C Part I – Authoritative Transmittal Information
18 Total number of Forms 1095-C submitted with this transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
19 Is this the authoritative transmittal for this ALE Member? If “Yes,” check the box and continue. If “No,” see instructions . . . . . . . . . . . . . . . .
20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
21 Is ALE Member a member of an Aggregated ALE Group? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If “No,” do not complete Part IV.
22 Certifications of Eligibility (select all that apply):
A. Qualifying Offer Method B. Qualifying Offer Method Transition Relief C. Section 4980H Transition Relief D. 98% Offer Method
Under penalties of perjury, I declare that I have examined this return and accompanying documents, and to the best of my knowledge and belief, they are true, correct, and complete.
Signature Title Date
For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61571A Form 1094-C (2015)
6 Country and ZIP or foreign postal code
10 Employer identification number (EIN)
14 Country and ZIP or foreign postal code
A T A O
e
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Question 1: Authoritative Transmittal
Question: If my company is a part of a control group and the parent company is filing the Form 1094-C on our behalf, should they check the box for the authoritative transmittal?
Answer: Yes. Each member of a control group will have a separate Form 1094-C associated with their EIN, and which will be the authoritative transmittal for that company.
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Question 2: Authoritative Transmittal
Question: When would a company not check the box for the authoritative transmittal?
Answer: A company may choose to file multiple Form 1094-C s and then it must aggregate its data on one Form 1094-C as the authoritative transmittal. For example, there are three divisions in a company. Each division fills out its own Form 1094-C and attaches it to the associated Form 1095-Cs for its employees. One of the Forms must aggregate the data for all three divisions and check the box as the authoritative transmittal. The other two divisions would not check the box.
DRAFT AS OF
DO NOT FILE
Form 1094-C Transmittal, Page 2
120216 Form 1094-C (2015) Page 2 Part III ALE Member Information—Monthly
(a) Minimum Essential Coverage Offer Indicator (b) Full-Time Employee Count
for ALE Member (c) Total Employee Count
for ALE Member (d) Aggregated Group Indicator
(e) Section 4980H Transition Relief Indicator
23 All 12 Months
Yes JuNo ne 16, (2a) 0Min1imu5m Essential Coverage
24 Jan
25 Feb
26 Mar
27 Apr
28 May
29 June
30 July
31 Aug
32 Sept
33 Oct
34 Nov
35 Dec
Yes if 70% (95% 2016+) of FTEs and dependents were offered MEC that month
Don’t count employees in
non-assessment period
Check “yes” in 2015 for non- calendar year plan transition relief months
Form 1094-C (2015)
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DRAFT AS OF
28 May
Form 1094-C Transmittal, Page 2
120216 Form 1094-C (2015) Page 2 Part III ALE Member Information—Monthly
(a) Minimum Essential Coverage Offer Indicator (b) Full-Time Employee Count
for ALE Member (c) Total Employee Count
for ALE Member (d) Aggregated Group Indicator
(e) Section 4980H Transition Relief Indicator
23 All 12 Months
Yes JuNo ne 16, 2015 (c) # of All
24 Jan
(b25) # oFfeb FTEs 26 Mar
DO NOT FILE Employees
Include part-
time and
Do not short-term 27 Apr
include employees
29 in nJuone n- 30 assJeulyssment
period
employees
Use first or last day of month
31 Aug
32 Sept
33 Oct
34 Nov
35 Dec
Form 1094-C (2015)
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DRAFT AS OF June 16, 2015
Form 1094-C Transmittal, Page 2
120216 Form 1094-C (2015) Page 2 Part III ALE Member Information—Monthly
(a) Minimum Essential Coverage Offer Indicator (b) Full-Time Employee Count
for ALE Member (c) Total Employee Count
for ALE Member (d) Aggregated Group Indicator
(e) Section 4980H Transition Relief Indicator
23 All 12 Months
24 Jan
25 Feb
26 Mar
27 Apr
28 May
29 June
30 July
31 Aug
32 Sept
33 Oct
34 Nov
35 Dec
Yes No
(d) Aggregate
DOGroNup InOdicatTor FILE Check the
box if your company is part of a control group
Form 1094-C (2015)
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Form 1094-C Transmittal, Page 3 DRAFT AS OF
120315
Form 1094-C (2015) Page 3 Part IV Other ALE Members of Aggregated ALE Group Enter the names and EINs of Other ALE Members of the Aggregated ALE Group (who were members at any time during the calendar year).
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, 2015 FILE
Name EIN Name EIN
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Part IV: Other ALE Members of Aggregated ALE Group
If your company is a member of a control
group, enter names and EINs of affiliates If ALE is not a member of a control group,
then ignore this section
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Form 1094-C (2015)
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Alternative (Simplified) Reporting Methods
* Must still complete 1095-C for IRS
Most employers will not use one of these methods
Qualifying Offer Method
EE receives qualifying offer for all months Qualifying offer- MV, FPL safe harbor Skip Line 15, 1095- C (cost) May provide general statement to EE’s rather than 1095-C *
Qualifying Offer Transition Relief
Employer certifies it may a qualifying offer to 95% of FT EE’s even if not all 12 months Same as to the left *
Section 4980H Transition Relief
Employers with 50 to 99 FTE’s
98% Offer Method
For all 12 months, employer offered 98% of EE’s affordable, MV MEC to EEs and dependents Skip identification and count of FT EE’s on 1094-C
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Form 1095-C Employee Information
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Purpose of 1095-C Form
Parts I and II:
Whether or not the employer owes a Penalty B for a specific employee for a specific month
Whether the employee potentially qualifies for a premium tax credit
Part III (self-insured only):
Used by the employee when they file their income taxes to prove the employee (and dependents / spouse) maintained “minimum essential coverage”
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Question: Forms Received by Employee
Question:
If my company is fully-insured, will the employer send the Form 1095-C to the employee or is the employer responsible for sending the Form 1095-C?
Answer:
If the employer is fully-insured, the insurance carrier will provide this information via Form 1095-B and the employer will provide the information via Form 1095-C so employees may be receiving two forms.
Remember: if the employer is self-insured, the information will be combined on one Form 1095-C.
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Steps to Complete Form 1095-C
Identify every employee who was full-time during 2015 and identify status for each month:
Employed (or not) for each month
Enrolled in coverage (or not) for each month
In a limited non-assessment period for each month
If self-insured, identify every non-FT individual enrolled in plan
Identify the type of coverage offered to the employee, the employee’s dependent(s)
and the employee’s spouse
MEC
Minimum Value or
No Offer
Know the cost of the least expensive, self-only MV coverage offered to that employee
Identify which affordability tests you used to determine if the coverage is affordable for each employee
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Key Term: Limited Non-Assessment Period
Only if EE is offered MV coverage by first day of month after limited non-assessment period:
Jan. – Mar. of first year as an ALE
Waiting period if employee is measured monthly
Waiting period if use the look-back method for EE classification
Initial measurement period and admin. period
Period following change in status
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DRAFT AS OF
Form 1095-C: Part II, Line 14: Offer of Coverage
Form 1095-C Department of the Treasury Internal Revenue Service
Employer-Provided Health Insurance Offer and Coverage ▶ Information about Form 1095-C and its separate instructions is at www.irs.gov/f1095c.
VOID
CORRECTED
600116 OMB No. 1545-2251
2015 Part I Employee 1 Name of employee 2 Social security number (SSN)
Applicable Large Employer Member (Employer) 7 Name of employer 8 Employer identification number (EIN)
3 Street address (including apartment no.) 9 Street address (including room or suite no.) 10 Contact telephone number
4 City or town 5 State or province 6 Country and ZIP or foreign postal code 11 City or town 12 State or province 13 Country and ZIP or foreign postal code
Part II Employee Offer and Coverage Plan Start Month (Enter 2-digit number):
14 Offer of August 6, 2015
All 12 Months Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
Coverage (enter required code)
15 Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value DO NOT FILE Coverage $ $ $ $ $ $ $ $ $ $ $ $ $ 16 Applicable Section 4980H Safe Harbor (enter code, if applicable)
Part III Covered Individuals
Form 1095-C Line 14 Indicator Codes
• Qualifying offer was provided for all 12 months (MEC/MV; FPL safe harbor) 1A
• MEC/MV offered (ever day of the month) to employee only 1B
1C • MEC/MV offered to employee; MEC offered to dependents but not spouse
• MEC/MV offered to employee; MEC offered to spouse but not dependents 1D
• MEC/MV offered to employee; MEC offered to spouse and dependents 1E
• MEC not providing MV offered to employee (i.e., skinny plan) 1F
• MEC offered by self-insured plan to employee who is not full-time / enrolled 1G
1H • No offer of MEC
• Qualifying Offer Transition Relief 1I
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DRAFT AS OF
Form 1095-C: Part II, Line 14: Offer of Coverage
Form 1095-C Department of the Treasury Internal Revenue Service
Employer-Provided Health Insurance Offer and Coverage ▶ Information about Form 1095-C and its separate instructions is at www.irs.gov/f1095c.
VOID
CORRECTED
600116 OMB No. 1545-2251
2015 Part I Employee 1 Name of employee 2 Social security number (SSN)
Applicable Large Employer Member (Employer) 7 Name of employer 8 Employer identification number (EIN)
3 Street address (including apartment no.) 9 Street address (including room or suite no.) 10 Contact telephone number
4 City or town 5 State or province 6 Country and ZIP or foreign postal code 11 City or town 12 State or province 13 Country and ZIP or foreign postal code
Part II Employee Offer and Coverage Plan Start Month (Enter 2-digit number):
14 Offer of August 6, 2015
All 12 Months Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
Coverage (enter required code)
15 Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value DO NOT FILE Coverage $ $ $ $ $ $ $ $ $ $ $ $ $ 16 Applicable Section 4980H Safe Harbor (enter code, if applicable)
Part III Covered Individuals
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Form 1095-C: Part II, Line 15: Employee Contribution Report lowest contribution for self-only MV coverage
Regardless of what tier of coverage employee is enrolled
If same in all 12 months, only enter once
Only fill out line 15 if MV was offered (otherwise affordability is a nonissue) :
One of the following codes was used on line 14:
1B: MV offered to EE only
1C: MV offered to EE and dependents
1D: MV offered to EE and spouse
1E: MV offered to EE, spouse and dependents
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DRAFT AS OF
Form 1095-C: Part II, Line 14: Offer of Coverage
Form 1095-C Department of the Treasury Internal Revenue Service
Employer-Provided Health Insurance Offer and Coverage ▶ Information about Form 1095-C and its separate instructions is at www.irs.gov/f1095c.
VOID
CORRECTED
600116 OMB No. 1545-2251
2015 Part I Employee 1 Name of employee 2 Social security number (SSN)
Applicable Large Employer Member (Employer) 7 Name of employer 8 Employer identification number (EIN)
3 Street address (including apartment no.) 9 Street address (including room or suite no.) 10 Contact telephone number
4 City or town 5 State or province 6 Country and ZIP or foreign postal code 11 City or town 12 State or province 13 Country and ZIP or foreign postal code
Part II Employee Offer and Coverage Plan Start Month (Enter 2-digit number):
14 Offer of August 6, 2015
All 12 Months Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
Coverage (enter required code)
15 Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value DO NOT FILE Coverage $ $ $ $ $ $ $ $ $ $ $ $ $ 16 Applicable Section 4980H Safe Harbor (enter code, if applicable)
Part III Covered Individuals
Form 1095-C Line 16 Indicator Codes
2A • Employee was not employed any day during the month
2B • Employee was employed, but not FT
2C • Employee enrolled in coverage offered by employer (if applicable, trumps all)
2D • Employee was in limited non-assessment period
2E • Employer pays fee to union pursuant to a CBA
2F • Employee waived coverage that was affordable coverage based on W-2 safe harbor 2G
• Employee waived coverage that was affordable coverage based on FPL safe harbor 2H •
Employee waived coverage that was affordable based on Rate of Pay safe harbor
2I • Non-calendar year transition relief applies for month
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Affordability Safe Harbors
Form W-2
• Box 1 • Retrospective in
application
Rate of Pay
• Hourly rate x 130 hours; or
• Monthly salary
Federal Poverty Line
• Based on 100% FPL • 2015, $93.17/mo
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Example: New Full-time Employee Enrolls in Plan
Facts: Full-time employee was hired on March 28th
Waiting period is 1st of Month following 60 days Employee enrolls in plan
1H: No offer of coverage 1E: MEC/ MV offered to EE; MEC offered to Dep. And Spouse
2A: Not employed any day of month 2D: Limited non-assessment period 2C: Enrolled in the plan
1H 1H 1H 1H 1H 1E 1E 1E 1E 1E
148
2A 2A 2D 2D 2D 2C 2C 2C 2C 2C 2C 2C
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Example: New Full-time Employee Declines Affordable MEC
Facts: Full-time employee was hired on March 28th
Waiting period is 1st of Month following 60 days Employee waives enrollment
1H: No offer of coverage 1E: MEC/ MV to EE; MEC to Dep.
2A: Not employed any day of month 2D: Non-assessment period 2H: Offer meets Rate of Pay Safe Harbor
1H 1H 1H 1H 1H 1E 1E 1E 1E 1E 1E 1E
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2A 2A 2D 2D 2D 2H 2H 2H 2H 2H 2H 2H
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Question: Mid-month Termination
Question: How do I report the month that an employee terminates employment if coverage ends on date of termination?
Answer: Remember that you report that an employee was offered coverage for a month under Part II of Form 1095-C only if the employee could be covered for all days of the calendar month. Enter code 1H, No offer of coverage, on line 14.
If the coverage would have continued if the employee had not terminated employment during the month, you will be eligible for relief from the employer mandate penalties. Enter code 2B, on line 16 for that month.
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Example: New Full-time Employee Declines Affordable MEC
Facts: Full-time employee was terminated on August 17th
Coverage ended on August 17th (COBRA not elected)
1H: No offer of coverage 1E: MEC/ MV to EE; MEC to Dep.
2A: Not employed any day of month 2B: Employee not a full-time employee 2C: Enrolled
1E 1E 1E 1E 1E 1E 1E 1H 1H 1H 1H 1H
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2C 2C 2C 2C 2C 2C 2C 2B 2A 2A 2A 2A
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Question: Reporting COBRA Coverage
Question: How should an employer report enrollment information for self-insured coverage provided to a non-employee COBRA beneficiary (for example, the former spouse of an employee), member of the board of directors, or retired employee?
Answer: For these individuals, a self-insured employer should enter code 1G, Offer of coverage to employee who was not a full-time employee for any month of the calendar year, on line 14 of Part II of Form 1095-C and completing Part III of Form 1095-C. Remember that Form 1095-C requires the recipient’s SSN on line 2 in all instances, so Form 1095-C cannot be used for covered individuals who have not provided a SSN to the employer. For example: a non-employee director
a terminated employee receiving COBRA coverage who terminated employment in a previous calendar year
a retired employee who terminated employment in a previous calendar year, or
a family member who is receiving COBRA coverage independent of the individual Use Form 1095-B as an alternative to Form 1095-C for an individual who was not an employee on any day
of the calendar year
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Question: Reporting COBRA coverage for fully insured plan
Question: How do I report the remaining months after an employee terminates from employment where there is a COBRA offer? For example, employee is covered as active employee, but then is terminated on May 15, 2015. Answer: COBRA elected:
Line 14: Jan thru Dec = 1E (offer of coverage)
Line 15: Jan thru April = Lowest-cost self-only premium; May thru Dec = Self-only COBRA premium
Line 16: Jan thru Dec = 2C (enrolled in coverage)
Then in following year (2016), no obligation to report
COBRA not elected:
Line 14: Jan thru April = 1E; May = 1H; June thru Dec = 1H
Line 15: Jan thru April = Enter Cost; May thru Dec = No entry
Line 16: Jan thru April = 2C; May = 2B; June thru Dec = 2A
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Form 1095-C: Part III, Self-insured Plans Part III: Lines 17 to 22
Only required if plan is self-insured
Must list all enrolled persons (FTE and part-time; spouses, dependents) if enrolled any day during the month
Include social security number
Can use date of birth instead of social security number after good faith
efforts are exhausted (three tries)
First effort should be made at time of enrollment
Second effort should be made before December 31 of the year in which open enrollment occurred
Third effort should be made before December 31 of the year the person is enrolled
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Form 1095-C: Part III, Self-insured Plans
600316 Form 1095-C (2015) Page 3 Name of employee Social security number (SSN)
Part III Covered Individuals — Continuation Sheet
(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is not available)
(d) Covered all 12 months
(e) Months of coverage
23 DR FT AS OF 24 August 6, 2015 26 DO NOT FILE 27
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34 Form 1095-C (2015
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Section 6056 Reporting: Practical Considerations
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Reporting: Information to Gather/Track in 2015
Name, address and SS/TIN for each FTE
Employees’ hours worked
Measurement period calculations
Offers of coverage (including waivers)
Months during which FTE was actually covered
Employee contribution amounts: Cost of coverage
Monthly basis
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Practical Considerations: Internal Internal groups to coordinate
HR
Benefits Administration
Payroll
Finance
Executives (if risking penalties)
Managers and Supervisors
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Practical Considerations: External External groups to coordinate
Payroll vendors
Benefit administration vendors
TPAs (if involved in plan administration, such as coverage offers and terminations, etc.)
Attorney
Tracking/reporting vendors
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Practical Considerations: Reporting Vendors
Vendors are available to assist!!
Tracking employee hours
Reporting (both 6055 and 6056)
Separately or together
NFP-preferred Vendors
Syncstream
Bswift
Next Generation
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Should I go with a vendor? Factors to consider:
Size of employer/number of employees
Internal capacity
Type of industry and workforce
Payroll/Benefit Administration vendor platforms
Ability to provide vendor with appropriate information
Control over EE work schedules/hours
Cost of vendor services
Time of year
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Miniature Case Studies: Vendor Use Needed Employer A: Vendor assistance
Smaller employer
Non-stable workforce
Few internal resources
Employer B: Vendor assistance
Larger employer (1000+)
Large variable hour/seasonal workforce
Already on vendor’s payroll system (bswift)
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Miniature Case Studies: Vendor Use Not Needed
Employer C: No vendor assistance
Mid-range employer (350-400)
Strong HR/Ben Admin team
Lots of control over EE schedule/hours
Employer D: No vendor assistance
Larger employer (1000+)
Big HR/Ben Admin team
Workforce fairly stable
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Next steps
Identify full time employees
Independent Contractors
Temporary staffing employees
Implement measurement periods for variable hour, seasonal, and part-time employees
Determine affordability strategy
Keep thorough records
Employees’ hours of service
Offer of coverage
Enrollments
Familiarize yourself with reporting forms and codes
Consider vendor solutions
Stay tuned for more guidance
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QUESTIONS?