ACA Reporting E-File Errors, Penalties & Exchange Notices

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1 ACA Reporting E-File Errors, Penalties & Exchange Notices

2 Agenda 1). Who is ACA Reporting Service? (quickly) 2). Setting the ACA Reporting Stage 3). The Process Leading up to E-Filing 4). E-Filing through the IRS A.I.R. System 5). A Penalties 6). Exchange Notices & B Penalties 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.

3 Who Is ACA Reporting Service One of the nations leading ACA Reporting Firms Our DNA is employee benefit knowledge Full Service ACA Reporting 1,000 + Employer Clients 1,000, Forms 98% Client Satisfaction Various reporting packages starting at $ C Code Calculator Best blog in the industry

4 What s New Two new releases for the marketplace Free Variable Hour Tracking Software 1 Hour ACA Reporting Experience

5 Setting the ACA Reporting Stage What is ACA Reporting trying to accomplish? 1). Individual Health Insurance Mandate (IRC 6055) 2). Play or Pay Employer Requirements (IRC 6056)

6 IRC 6055 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) Also used by self-insured employers with under 50 employees C Forms: Issued by Self Insured Employers (form 1095 C, part 3)

7 IRC 6055 The IRS Then Pulls All Of The Data Together. & Knows Each Persons Full Enrollment Example Person

8 Impact to Form 1040 Specifically, on the form 1040 of individuals, there is a line (shown below) and they will need to complete as part of filing their taxes.

9 IRC 6056 How will the IRS know if each Large Employer offered qualifying coverage and affordable coverage. C Forms: Issued by all Large Employers & Aggregated Groups - Form 1094C is the transmittal - Form 1095C is specific for each employee Insurance carriers do not perform this function

10 IRC 6056 Specifically, section 2 of form 1095-C is used by the IRS to ensure affordable coverage was offered to full time employees. Visit Learn Tab on our website for more details.

11 E-Filing to the IRS Prior to the end of June 2016, ALEs must E-File their forms 1094 & 1095 to the IRS via the A.I.R. System Remember this is Protected Health Information and Requires HIPAA and HITECH Compliance Responsibility always resides with the employer Quality of your reporting will be come evident

12 E-Filing Errors There are hundreds of various possible errors with your filings but they will fall into 3 different categories of what to do about it: Your E-Filing is rejected (must correct & resubmit) Your E-Filing is accepted with errors (OK for filing deadline, submit error corrections timely. Unofficially we have heard Nov. Some of these errors are no doubt on the part of the A.I.R. system.) Your E-Filing is fully accepted

13 E-Filing Status Nationally As of the beginning of May, 2016 there had only been roughly 40,000 completed E-Filings in the entire country. In fact, in one day alone our company accounted for 15% of the nations total E-Filing.

14 E-Filing Status Nationally The quality of your data in reporting will play an important role. Many employers did not pay much attention to code combinations, etc. Now this will cause many problems. Remembering Penalties are Built in and Automatic (covered shortly).

15 E-Filing Status Nationally Understanding your vendor is also very important for employers during this stage: Confirm your E-Filing and request a copy of the IRS acknowledgement Customer service and knowledge about everything ACA reporting related is critical Many vendors will simply send XML code back to the employer that they will need to decipher in order to determine what needs to happen next

16 A Penalties Once the IRS accepts your E-Filing and it is correct, the first thing that will be processed is A Penalties. Amounts for 2015 are $2,080 for failing to offer minimum essential coverage to a full-time employee $ per employee per month (indexed for inflation)

17 Transmittal Form 1094-C A Penalties

18 A Penalties Example #1: Assumes A Type Transitional Relief Month MEC? Full Time Employees A' Penalty Jan No 95 $0 Feb No 95 $0 Mar No 95 $0 Apr No 95 $0 May No 95 $0 Jun No 95 $0 Jul No 95 $0 Aug No 95 $0 Sep No 95 $0 Oct No 95 $0 Nov No 95 $0 Dec No 95 $0 TOTAL $0

19 A Penalties Example #2: Assumes B Type Transitional Relief Month MEC? Full Time Employees A' Penalty Jan No 150 $12,133 Feb No 150 $12,133 Mar No 150 $12,133 Apr Yes 150 $0 May Yes 150 $0 Jun Yes 150 $0 Jul Yes 150 $0 Aug Yes 150 $0 Sep Yes 150 $0 Oct Yes 150 $0 Nov Yes 150 $0 Dec Yes 150 $0 TOTAL $36,399 Penalties are automatic!

20 B Penalties When an Applicable Large Employer (ALE) does not offer affordable coverage to a full time employee AND. That employee goes to the exchange and receives a subsidy for health coverage THEN. The employer will own a B penalty for that employee of $3,120 for the 2015 filing year ~ $260 per employee per month

21 Exchange Notices Beginning in June, the state and federal healthcare exchanges will begin to issue employer letters regarding employees who received a subsidy from the exchange for health coverage.

22 Exchange Notices These letters will be based upon the information the exchange received from the employee at the time they signed up for health coverage and received a subsidy.

23 Exchange Notices Appeals Employers have 90 days to respond and appeal to the exchange in an effort to avoid the B penalty. Employers get 1 chance only to appeal.

24 Exchanges Appeal Determinations The exchange has 90 days to make a final determination and then. The employer will be due to pay the penalty, or The employee will be due to pay back the subsidy

25 Resources to keep in mind Not a client & need help? Call us at or support@acareportingservice.com Form 1095-C Code Calculator (free) Variable Hour Tracking Software (free) 1 Hour ACA Reporting Experience Learn Blog Partnering Questions?

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