1. Affordable Care Act Compliance
Tracking and Reporting Made Simple

2. 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.

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

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

5. 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

6. Ongoing Tracking

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

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

9. 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

10. Reporting Forms Required

11. Reporting Forms Required Cont’d

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