ONEPOINT | HUMAN CAPITAL MANAGEMENT ACA Compliance – Ready for 2015 Filing? Presented by: Lisa Slook, PHR SHRM – CP PPACA Certified by NAHU Nevada Life & Health License (866) x 109

 High level overview  Not legal advice or final compliance guidance  Not a political discussion  Possible parties that should be involved in this process include: Your Insurance Broker, CPA, Legal Counsel, HR and/or Benefit Administrator, Payroll, Finance, and any other Compliance Personnel Agenda:

Employer Mandate – Who?  Any employer with 50 or more full-time and full-time equivalent (FTE) employees in the preceding calendar year.  Applicable Large Employer (ALE)  FT/Full-Time Equivalent vs. Full-Time Classification  If you had, on average, less than 50 full-time and full-time equivalent (FTE) employees in 2014 you are off the hook (Transition Relief – 6 months).  If you were close last year and will go over this year, prepare now.

Determining your FT/FTE Count  Not as simple as taking all of your service hours and dividing it by 1560 (130 hours * 12 months)  For the previous calendar year by each month: Calculate number of full time employees FTE = (monthly part-time service hours) ÷ 120 Individuals are capped at 120 service hours per month.  All of those hours are then divided by 120 to determine your FTE count for each month which is then added to your full-time number for each month and averaged at the end of the year.

Penalties IF an employee is offered a plan that is 1.Not affordable 2.Does not provide minimum essential coverage 3.Does not meet the minimum value requirements 4.Does not cover dependents 5.Did not offer coverage to enough of your employees AND the employee receives a tax credit you WILL be hit with a penalty

The Trade Preferences Extension Act of 2015 (“Trade Bill”) signed into law on June 29, significantly increased potential penalties for employers and insurers that fail to comply with the Affordable Care Act (ACA) reporting requirements, beginning in early The IRS has stated they will not penalize employers that make a “good faith effort” to report and report on time in However, if you do not file at all you will be penalized.

How do I avoid a penalty?:  Stay in compliance.  Ensure you are offering every eligible employee and their dependents coverage that is minimum value provides minimum essential coverage and meets the affordability safe harbors.  Ensure you are able to prove that you offered coverage that was affordable and compliant with ACA regulations and keep track of employees who WAIVED coverage.  Complete the reporting requirements by keeping track of all of this information on a monthly basis.

Reporting Requirements – Data, Data, Data  Employer Information  Employee Demographics  Report “Offer of Coverage” information using one of nine different coding options.  Report “Lowest Cost Share” of the employee only coverage that was offered to the employee.  Report “Safe Harbor Used and Other Relief” using one or more codes that apply out of the nine coding options.  Self-Insured employers have additional reporting requirements.

How do I know if we are compliant?  How many FT/FTE employees do you have?  Do you know if the owners of your company have common ownership within any other company? *May push you over 50/100 FTE  Do you know if any of your employees have gone to the exchange, enrolled in benefits and qualified for a tax subsidy?  Do you have the tools to do a historical look back at payroll/time sheets?  Do you have the data or reporting about offers of coverage made to employees to provide evidence of compliance?  Have you familiarized yourself with the 1094-C and 1095-C forms?

How do I know if we are compliant? – Continued  Do you know which employees during your standard measurement period had on average 30+ service hours each week or more or 130+ service hours per month?  Do you know when new variable hour employee’s initial measurement periods are ending? Are they eligible to continue benefits after their stability period?  Do you know if you offered affordable coverage to your employees?  Do you know if that coverage was minimum value and provided minimum essential coverage?

Have a plan and execute it now.  Do you have the technology in place to assist you with compliance?  Do you know if the coverage offered to your employees was affordable?  Do you know how many employees each month were considered full- time?  Are you tracking service hours to determine eligibility?  If you needed to complete the 1094-C and 1095-C form today, can you?  Don’t wait – the reporting is based on monthly information which may not be currently in the OnePoint system.  You will need to audit the forms and are ultimately responsible for your own compliance.

Calculates Monthly Service Hours, Status Per Month, Calculates the ACA Status, Provides Compliance Alerts, Approaching FT/Downgrade to PT, Keep Track Measurement, Administrative and Stability Periods

ONEPOINT | HUMAN CAPITAL MANAGEMENT Questions? Interested in learning more about the ACA Module? Deadline to sign-up is October 16 th Please contact your Customer Service or Sales Representative Call:

1H 2A2D 2C H1C 1E 2A Employee Hired 2/20/15 – Not employed in January so the code is 1H on Line 14 and 2A on Line 16 Employee was in a “Limited Non-Assessment Period” Feb, March, April, May – Waiting Period Employee was offered coverage that was minimum value to the employee and dependents (not spouse) Plans changed with plan year starting 7/01 and a plan is now offered to the spouse and dependents Employee terminated 11/30/15 Employee share of self-only coverage changed when the plan year changed.