Affordable Care Act Reporting Seminar August, 2015 The materials and information have been prepared for informational purposes only. This is not legal advice, nor intended to create or constitute an attorney-client relationship. Before acting on the basis of any information or materials, readers who have specific questions or problems should consult their attorney.
Meeting Objectives... 1). We will NOT try to convert you into an ACA Reporting Expert. Promise! 2). We WILL tell you the basics of what most people need to know. 3). We WILL leave plenty of time for your questions.
Top 5 Misconceptions Regarding ACA Reporting 1). I’m fully insured so my insurance carrier is handling this. 2). My payroll company will take care of this reporting. 3). Purchasing software is the best solution for all employers to complete this reporting. 4). This reporting is simple, right? 5). ACA Reporting doesn’t involved protected health information (PHI).
A Quick (non-attorney) Overview What Did The Affordable Care Act Accomplish? 1). Individual Health Insurance Mandate (IRS 6055) 2). Pay or Play Employer Requirements (IRS 6056)
How will the IRS know if each person is covered by a health insurance plan for all months of the year? ‘A’ Forms: Issued by the Healthcare Exchanges (form 1095 A) ‘B’ Forms: Issued by Health Insurance Carriers (form 1095B) ‘C’ Forms: Issued by Self Insured Employers (form 1095 C, part 3) - this includes employers with under 50 employees Individual Mandate Reporting IRS 6055
Then, the IRS pulls all of these forms together to ensure every individual had coverage for every month of the year. If not, there will be a penalty. Individual Mandate Reporting IRS 6055
How will the IRS know if each Large Employer offered qualifying coverage and affordable coverage. ‘C’ Forms: Issued by all Large Employers - Form 1094C is the transmittal - Form 1095C is specific for each employee Employer Pay or Play Reporting IRS 6056
Fully Insured Carriers Will NOT Do This For You! Employer Pay or Play Reporting IRS 6056
CODE Information Line 14 codes: 1A, 1B, 1C, 1D, 1E, 1F, 1G, 1H or 1i Line 15 only completed in certain situations Line 16 codes: 2A, 2B, 2C, 2D, 2E, 2F, 2G, 2H o 2i Codes Vary Based Upon These factors for every month impact the associated codes used: full time, part time, part time benefit eligible, who was enrolled and when, plan costs, type of coverage offered, who it was offered to, transitional relief, various safe harbors, initial measurement periods, limited non-assessment periods, multi- employer rules and non-calendar year renewal plans.
OK... So I Need To Report. Now What? Correct Reporting Requires Payroll & Medical Plan Enrollment Information Often This is Not In The Same Place
How To Complete Reporting (Strategy) 1). Do you have payroll and benefits administration with the same vendor? Can be an easy option Often expensive 2). Consolidate benefits enrollment information to your current payroll vendor. Offers the advantage of using a vendor you already work with Many payroll vendors aren’t taking new clients Others are not prepared, or plan to start developing late in the year Can be expensive Not an available option if you perform payroll in-house
How To Complete Reporting (Strategy) 3). Send payroll information to your current benefits administration vendor. Offers the advantage of using a vendor you already work with Many large software systems do not offer ACA reporting Not an option if no benefits administration system is used Can be expensive 4). Use a Stand Alone, Full Service ACA Reporting Vendor. Highly flexible solution that can work regardless of your situation Much less expensive option Experts specifically in ACA Reporting, and typically have a much greater in-depth knowledge specifically of this requirement
Our Stand Alone, Full Service ACA Reporting
Hipaa & Hitech Compliant ACA reporting contains protected health information Mailing of forms must be secured We enter into business associate agreements with your company E-Filing of forms to IRS included Additional Services Available Hipaa secure form mailing to employees Personal ACA reporting account manager 1 st class customer service experience
Most Frequent Q & A 6056 reporting ONLY applies to applicable large employers (50+ or 50+ equivalents) Reporting must be complete and given to employees (securely) by January 31 st Forms? Must be e-filed to IRS by March 31 st. Under 250 Forms? You have the option to submit paper forms to the IRS by February 28 th. What payroll information is needed? Employee name, SSN, address, hire date, termination date, and if they were full-time, part-time, or part-time benefit eligible. What enrollment information is needed? Enrollee name, SSN, address, coverage start date, coverage end date and the type of person enrolled (employee, dependent, retiree, COBRA, etc.) Yes, reporting must be done even if you will not owe a penalty (a or b penalty). All employees who were full time for ANY day of the calendar year must receive a form.
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