Affordable Care Act Compliance Tracking and Reporting Made Simple

Employer Shared Responsibility Tax Applies to… Applicable Large Employers 50 or more Full-Time Equivalent employees in preceding year Full-Time Equivalent employees = Non-Full-Timers hours/120 each month Add number of Full-Timers to equivalent employees to get number of FTEs Note*: Leased employees, seasonal employees, “common-law employee” standard Who does the tax apply to? All about being an applicable large employer…. 50 or more Full-Time equivalents in the preceding year For many organizations – new definition employee who works 30 or more hours per week. Determine FTEs – total part-time hours divided by 120 each month and add to the Full-Time employees Add these to together to get FTEs Note – special potential issues around leased employees etc.

Applicable Large Employer are Responsible for… Annual IRS Reporting Employee Tracking

Who Is and Who Is Not Full-Time?... Important to Know…

Tracking – ‘Look Back’ Methodology Look Back - Regulations outline the process of tracking of employee status Concept: If an employee is determined to be Full-Time during a Measurement Period, then the employee is treated as Full-Time during a subsequent Stability Period If an employee is designated as Full-Time, then tracking is not required IRS Annual Reporting…. So then the question is how do we know who is full-time when This is complex - but is a key point in the tax assessment and really need to be address today. Theory: Intended to provide certainty, especially for employers with Ongoing , New Variable Hour Reality: Extraordinarily complex rules; not clear what documentation must be maintained; use of lookback measurement modifies health plan eligibility rules and will require plan amendments and revised communications Designated Full-Time do not require tracking but must be reported

Ongoing Tracking

Chart Your ACA Course 9/19/20189/19/20189/19/2018

ACA Risk Factors Applicable Large Employer Part-Time and/or Seasonal Employees Variable schedules Turn-over Number of employees Control Group

Reporting Requirements Per Employer IRS Code Who Report and/or Provides Statement Forms Filed with the IRS Statement Provided to Employee Applicable Large Employer – Not Offering a Health Plan 6055 No Reporting Required N/A 6056 1094-C &1095-C (no part III) 1095-C (no part III) Applicable Large Employer – Offering an Insured Health Plan Insurer 1094-B & 1095-B 1095-B Applicable Large Employer – Offering a Self-Funded Health Plan 1094-C & 1095-C 1095-C

Reporting Forms Required

Reporting Forms Required Cont’d

ACA Compliance & IRS Reporting Applicable Large Employer Status Compliance Planning Strategies Documentation Regulatory Reporting Audits Liabilities Forms and Content