1. Presented by: Darcy L. Hitesman
October 29, 2015
It’s All related
1094/1095 Public Sector Filing Details
Presented by:
Darcy L. Hitesman

2. Employer Shared Responsibility Payments
G-PRS 10/29/2015
It’s All Related…
Tracking “Full-time”
1094/1095 Reporting
Employer Shared Responsibility Payments

3. Overview & Comments Forms 1094-C/1095-C Public Sector
Two purposes (§§6056 and 6055)
Determines what gets completed
Public Sector
2016 Filing for 2015 Calendar Year
Focus on Key Aspects of the Forms
Information needed to complete forms
How to complete forms
Comprehensive but not exhaustive
Not Addressing:
Which employers are ALEs
Deadlines and methods for filing
Notification options and deadlines
Penalties for failure to file

4. Preliminary Steps LET’S DO THIS NOW.
Mark sure you are an applicable large employer (ALE)
100 or more FTEs
50-99 FTEs
Know what plans are involved
Major medical
Some HRAs
Know whether plan(s) is insured or self-insured
LET’S DO THIS NOW.

5. Preliminary Steps YOU CAN DO THIS NOW.
Determine who will be completing/submitting the filing
Read and mark final 2015 instructions (issued 9/16/2015)
Determine what lines on Forms need to be completed
Form 1094-C:
Form 1095-C:
Cross through lines on Forms not required to be completed
Focus on what you need to do
YOU CAN DO THIS NOW.

6. Are You Part of an Aggregated ALE for 2015?
G-PRS 10/29/2015
Are You Part of an Aggregated ALE for 2015?
“ALE Member”
The filing requirement applies to the ALE member
Single employer
Aggregated ALE
Controlled group concept
Each employer that is part of the controlled group is an ALE member
Some lines are only completed by members of an aggregated ALE

7. Are You Part of an Aggregated ALE for 2015?
G-PRS 10/29/2015
Are You Part of an Aggregated ALE for 2015?
TO DO:
Map who you provide coverage to
Map “related” entities (whether or not provide coverage to)
Determine whether part of same controlled group
Determine size of aggregated ALE (each ALE member is labeled based on entire controlled group)
Identify how many filings and with respect to whom

8. Designated Governmental Entity (DGE)
G-PRS 10/29/2015
Designated Governmental Entity (DGE)
Special provision for public sector
Allows another public sector entity to file on behalf of an ALE member
Not a consolidated return
Each ALE member has own set of filings
Can slice and dice
Designation process
In writing and signed by both ALE and DGE
DGE agrees to be responsible for reporting on behalf of ALE
Identifies categories of employees for which DGE will report

9. Designated Governmental Entity (DGE) - Example
G-PRS 10/29/2015
Designated Governmental Entity (DGE) - Example
ABC County is located in Minnesota
All county employees eligible for county’s SIHP through service coop
ABC County designates service coop as DGE
Full designation (i.e., §§ 6055 and 6056 information)
Service coop (DGE) files authoritative transmittal for county

10. Designated Governmental Entity (DGE) - Example
G-PRS 10/29/2015
Designated Governmental Entity (DGE) - Example
ABC County is located in Minnesota
Sheriff’s deputies eligible for PEIP
Rest of county employees eligible under SIHP of County (not service coop)
ABC County designates PEIP as DGE for sheriff’s deputies eligible through PEIP
Partial designation
County Files Authoritative Transmittal For County
indicating employee level data (including sheriff’s deputies) and rest of county employees
PEIP (DGE) files
transmittal for sheriff’s deputies eligible for PEIP

11. Form 1094-C Part I: ALE Information
G-PRS 10/29/2015
Form 1094-C Part I: ALE Information
Form 1094-C is a “transmittal” form
Accompanies 1095-C forms when submitted to IRS
ALE Member
Lines 7 and 8 identify the person “responsible for answering any questions”
Lines 9 – 15 for governmental entities only

12. G-PRS 10/29/2015
1094 – C Form

13. Form 1094-C Part I: ALE Information
G-PRS 10/29/2015
Form 1094-C Part I: ALE Information
Line 18, total number of 1095-C forms transmitted under this 1094-C
Can be more than one transmittal
Line 19, Authoritative transmittal
One transmittal must be designated “authoritative” and report aggregate ALE Member-level data
If only one transmittal being filed, it is the “authoritative” transmittal
Lines 20 – 22 completed only if authoritative transmittal

14. Form 1094-C Part II: ALE Member Information
G-PRS 10/29/2015
Form 1094-C Part II: ALE Member Information
Line 20, total Forms 1095-C for ALE member
Compare to Line 18; if single employer filing only one 1094-C, Line 20 should be same as 18

15. Form 1094-C Part II: ALE Member Information
G-PRS 10/29/2015
Form 1094-C Part II: ALE Member Information
Line 21, whether part of Aggregated ALE Group (i.e., controlled group)
Need to know whether are or are not part of Aggregated ALE Group
Document analysis
If not part of Aggregated ALE Group, do not have to complete Part IV

16. Form 1094-C Part II: ALE Member Information
G-PRS 10/29/2015
Form 1094-C Part II: ALE Member Information
Line 22, Certifications of Eligibility [later slide]
Remember – only completing Line 22 if “authoritative” transmittal (see Line 19)
The Four Boxes
Qualifying Offer Method
Qualifying Offer Method Transition Relief
Section 4980H Transition Relief
98% Offer method
Employer determines whether apply and whether want to take advantage
Check all that apply
Important: Boxes checked significantly impact what needs to be completed and how.

17. Section 4980H Transition Relief
G-PRS 10/29/2015
Section 4980H Transition Relief
1094-C Part II, Line 22, Box C checked “yes”
Special penalty related rules
“Transition” because not permanent
ALEs with employees
ALE with 100 or more FTEs
Penalty assessable beginning 2015
For 2015, “minus 80 freebies” instead of “minus 30 freebies”
Must complete 1094-C, Part III, column (e)
Note: Do not automatically get this relief. Must check the box!

18. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Column (a) Minimum Essential Coverage (MEC) Offer Indicator
Check “yes” or “no”
Where 1094-C Part II, Line 22, Box C checked “yes”
Box C is Section 4980H Transitional Relief
ALE with 100 or more employees (i.e., penalty assessable in 2015)
For 2015, “minus 80 freebies” instead of “minus 30 freebies”
Check “yes”

19. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Column (b) Full-time Employee Count
If checked 1094-C, Line 22, Box D (98% Offer Method), do not complete
Number of full-time employees for each calendar month minus full-time employees in a Limited Non-Assessment Period (LNP)
NOT related to full-time employees that took coverage
Used to calculate Penalty (a)
LNP – Recognized period during which not penalty assessable
Examples include waiting period, first month of employment

20. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Use same day each month
First day of calendar month
Last day of calendar month
First day of first payroll period in month
Last day of first payroll period in month
If the same number for each calendar month, may use “all 12 months” instead of month by month

21. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Column (c) Total Employee Count
Total number of employees for each calendar month
Full-time, part-time, seasonal, temporary, LNP, etc.
NOT related to those that took coverage
Use same day each month
Same method options as column (b)
If the same number for each calendar month, may use “all 12 months” instead of month by month

22. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Column (d) Aggregated Group Indicator
Complete if checked “yes” on 1094-C, Part II, Line 21
Line 23 if all information the same for all 12 months
Or lines 24 – 35
Complete month by month
If check any box “yes”, must complete 1094-C, Part IV

23. Form 1094-C Part III: ALE Member Info Monthly
G-PRS 10/29/2015
Form 1094-C Part III: ALE Member Info Monthly
Column (e) Section 4980H Transitional Relief Indicator
If checked “yes” on 1094-C, Part II, Line 22, Box D
Availability of relief is employer responsibility to determine
Code A if qualify for and are requesting relief (not penalty assessable in 2015)
Code B if qualify for and are requesting 100 or more relief (penalty assessable but lower thresholds for 2015)
Cannot be eligible for both

24. Form 1094-C Part IV: Other ALE Members of Aggregated ALE Group
G-PRS 10/29/2015
Form 1094-C Part IV: Other ALE Members of Aggregated ALE Group
COMPLETE ONLY IF PART OF AGGREGATED ALE GROUP
If checked “yes” on 1094-C, Part II, Line 21
Complete if part of aggregated ALE group at any time during calendar year
List top 30 ALE members in descending order based on highest average full-time employees
ALE member as defined in instructions
If entity in controlled group does not have employees, then not considered ALE member
Must also complete 1094-C, Part III, column (d)

25. G-PRS 10/29/2015
1095 – C Form

26. Form 1095-C Part I: Employee and ALE Members
G-PRS 10/29/2015
Form 1095-C Part I: Employee and ALE Members
One for each “full-time” employee
Full-time under Health Care Reform
Regardless of whether actually covered
Full-time employee for any month of the calendar year
If self-insured, also for each other employee (i.e., other than full-time) actually covered
Because reporting as ALE and as provider
If self-insured, also for any other person actually covered
Alternatively, can use B series [more later]
Lines 7 – 13 need to match Form 1094-C entries

27. Form 1095-C Part II: Employee Offer and Coverage
G-PRS 10/29/2015
Form 1095-C Part II: Employee Offer and Coverage
Line 14: Offer of Coverage
Look at possibilities listed in 2015 instructions
First column if all 12 months
Otherwise, each calendar month
NOT related to who actually takes coverage; just about the offer

28. Form 1095-C; Line 14 1A Qualifying offer; matches Line 22 of 1094-C 1B
G-PRS 10/29/2015
Form 1095-C; Line 14 1A
Qualifying offer; matches Line 22 of 1094-C 1B
MEC/MV employee only 1C
MEC/MV employee; MEC to dependent children 1D
MEC/MV employee; MEC/MV to spouse but not dependent children 1E
MEC/MV employee; MEC/MV to spouse; MEC/MV to dependent children 1F
MEC not MV to employee or employee plus 1G
Part-time self insured for all months of employment 1H
“no offer” not offered any or not offered MEC 1I
Relates to 1A
COBRA clarification instructions clarify offer of COBRA to former employee is not an “offer” reported on Line 14. [later]

29. Form 1095-C Part II: Employee Offer and Coverage
G-PRS 10/29/2015
Form 1095-C Part II: Employee Offer and Coverage
Line 14 Example: FT employee hired on June 15, 2015; coverage available first of month following 30 days employment
June – July 1H for months prior to first coverage month
August – December 1E months offered
Compare to employee covered for entire year – all boxes would be 1E so use “all 12 months”

30. G-PRS 10/29/2015
Form 1095-C; Line 15
* Only complete if Line 14 is 1B 1C 1D or 1E
Employee’s portion of the cost for self-only lowest cost option
What hypothetical employee would pay; not what a particular employee actually pays for his/her coverage selection
If self-only of base coverage is 100% employer paid, enter 0.00

31. Form 1095-C Part II: Employee Offer and Coverage
G-PRS 10/29/2015
Form 1095-C Part II: Employee Offer and Coverage
Line 16 Example: FT employee hired on June 15, 2015; coverage available first of month following 30 days employment; employee actually enrolls
Jan – May 2A
June and July 2D (LNP)
August – Dec 2C
Compare to FT enrolled all year – 2C

32. Form 1095-C Part II: Employee Offer and Coverage
G-PRS 10/29/2015
Form 1095-C Part II: Employee Offer and Coverage
Line 16: Applicable Section 4980H Safe Harbor
Note: “if applicable”
Code 2 series –
Safe harbor codes “and other relief”
Addresses which to use when more than one applies
If none apply, leave blank
First column if “all 12 months”
Otherwise month by month

33. G-PRS 10/29/2015
Form 1095-C; Line 16
* Determines exposure for category b
Only one code entered event if more than one appears
If none apply, leave blank 2A
Not employed on any date during calendar month 2B
Not a full-time employee for month
*if actually covered, use 2C *if don’t know, use 2D 2C
Enrolled in MEC 2D
Limited non-assessment period
2D trumps 2B 2E
Eligible for multiemployer plan [later]
2F, 2G, 2H
Using an affordability safe harbor 2I
Non-calendar plan year months before 2015 plan year starts [later]