1. GENERAL ACA REPORTING REQUIREMENTS Christopher Bailey – MIIA Health Trust Manager

2. ACA Added 2 sections to Internal Revenue Code Section 6056 –  Requires Applicable Large Employers (50+ employees) to report concerning the coverage they offered to full-time (averaging 30 hours per week) employees Section 6055 –  Requires providers of coverage to report coverage information for the individuals (and their dependents) to whom Minimum Essential Coverage is provided 2

3. PURPOSE § 6056 –  Enables IRS to enforce Employer Mandate and  Helps establish whether employees are eligible for subsidized coverage through the Exchange  Forms 1094-C and 1095-C § 6055 –  Enables IRS to enforce the Individual Mandate  Allows individuals to demonstrate they have coverage and avoid penalties  Forms 1094-B and 1095- B and Part III of Form 1095-C 3

4. Who Performs §6055 Reporting  Insured Coverage  Self-Insured Coverage  Joint Purchase Group (Self-Insured Coverage)  MIIA Health Trust (Self-Insured Coverage)  GIC Municipal Coverage  Insurance carrier on Forms 1094-B and 1095-B  Employer on Part III of Form 1095-C  MIIA Health Trust on Forms 1094-B and 1095-B  GIC (as Designated Governmental Entity) on Forms 1094-B and 1095-B 4

5. Form 1095-B Form 1095- B includes:  Subscriber’s Name, Address and SSN  Employer’s Name, Address and EIN  MIIA Trust’s Name, Address, EIN and Contact Number  Subscriber and Dependents, SSN or DOB, and Months covered 5

6. If filing Form 1095-B must:  Mail a copy of her/his Form 1095-B to each subscriber on or before February 1, 2016 (January 31 is a Sunday)  File a copy of Form 1095-B for every subscriber plus Form 1094-B (transmittal form indicating the number of Forms 1095-B being filed) with IRS on or before February 29, 2016 (March 31, 2016 if filing electronically) 6

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8. DEADLINES February 1, 2016 – deadline for serving Form 1095-C upon each full-time employee and, if employer completes Part III of Form 1095-C, upon every subscriber (usually January 31) February 29, 2016 – deadline for filing Forms 1095-C for each full-time employee plus Form 1094-C transmittal form with IRS March 31, 2106 – deadline for filing C forms if filing electronically MUST FILE ELECTRONICALLY IF FILING 250 OR MORE FORMS 1095-C 8

9. Service of Form 1095-C Upon Employees Delivery generally by first class mail Delivery by e-mail permitted if: a.) employee affirmatively consents to receive the statement in an electronic format b.) Individual may consent on paper or electronically (by e-mail). If consent is on paper, individual must confirm consent electronically 9

10. FORM 1094-C - Form 1094-C is a transmittal form to be filed with the IRS (along with the employee statements (Forms 1095-C)). Form 1094-C requires the following information:  Identifying information about the employer submitting Forms 1094-C and 1095-C  Whether the Form 1094-C is the “authoritative transmittal”  Whether the employer is part of a controlled-group of entities  Whether the employer qualifies for “transitional relief” from the Employer Mandate or whether the employer qualifies for alternative simplified reporting Part I: Part II: 10

11.  Indicates which months the employer offered minimum essential coverage  The number of the Employer’s full- time employees in each calendar month  The total number of the Employer’s employees in each calendar month  Whether the employer is part of a controlled-group of entities in each calendar month  Whether the employer qualifies for transitional relief from the Employer Mandate in each calendar month  The names and EINs of each entity that was in the same controlled-group of entities at any point in the calendar year Part III:Part IV: 11

12. Form 1095-C is the employee-specific form to be provided to each full-time employee and requires the following information:  Identifying information about the full-time employee or responsible individual  Identifying information about the employer  Information about the employer’s offer of coverage  Dollar amount of the employee’s share of the lowest-cost monthly premium for self-only minimum essential coverage offered by the employer  Whether the employee was enrolled in coverage or, if not, an indicator code regarding why the employee was not enrolled in coverage Part I:Part II: 12

13. Identifying information regarding the subscriber and dependents Employers offering: 1.) Insured Coverage 2.) Coverage through MIIA Health Trust 3.) Coverage through GIC will not complete Part III (and will not check the box at the beginning of Part III) as the insurer, the Trust, or the GIC will be supplying this information on Form 1095-B Part III: 13

14. 2016 Relief from Penalties Penalties will not be imposed on reporting entities that can show good faith efforts to comply  Incorrect/incomplete information reported in 2016 forms (related to 2015 coverage)  Failure due to what IRS considers “reasonable cause”  No good faith effort to comply  Failure to timely file information return or furnish statement  Penalty for no good faith effort to comply is $250 per occurrence Relief Available for:Relief Not Available 14