Affordable Care Act Reporting Requirements
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1 Affordable Care Act Reporting Requirements Amy Magee Senior Attorney for Community Colleges Texas Association of School Boards. Texas Association of School Boards, Inc. All rights reserved.
2 Goals How reporting applies to your college district Form 1095-C Form 1094-C
3 Background Definition of full-time employee and workforce size calculations Requirement to offer coverage to full-time employees Affordability requirement
4 Background Definition of full-time employee and workforce size calculations Requirement to offer coverage to full-time employees Calculating hours of service: Services-for-Community- Colleges/documents/calculating_hours_of_service_.pdf Determining full-time status: Policy-Services-for-Community- Colleges/documents/determining_full_time_status_.pdf Affordability requirement
5 Background What Texas Community College Officials Should Understand About the Affordable Care Act: Services-for-Community- Colleges/documents/understand_about_the_ACA_.pdf Definition of full-time employee and workforce size calculations Requirement to offer coverage to full-time employees Affordability requirement
6 Materials
7 Materials
8 Materials
9 Materials
10 HOW REPORTING APPLIES TO YOUR COLLEGE DISTRICT Purpose of reporting Which college districts must report Reporting period Deadlines
11 Purpose of Reporting Employer Full-time status Offer of coverage Affordability Plan enrollment (selfinsured) Employee Eligibility for premium tax credits Coverage for self and dependents Page 1 of instructions: Purpose of Form
12 Separate But Related Shared Responsibility Requirements Reporting Requirements
13 Which College Districts Must Report District size Fully-insured Self-insured < 50 full-time employees* Employer reporting does not apply Form 1095-B on all persons who enrolled in coverage >/= 50 fulltime employees* Form 1095-C for each fulltime employee Form 1095-C for each fulltime employee AND Form 1095-C for each employee who was not fulltime but who enrolled in coverage * Including workforce extender (full-time equivalents as defined by ACA) Pages 1-2 of instructions: Who Must File
14 Higher Education Group Benefits Program
15 Higher Education Group Benefits Program HealthSelect of Texas: self-insured HMOs and Medicare Advantage: fully-insured
16 Higher Education Group Benefits Program HealthSelect of Texas: Delegate enrollment reporting to ERS HMOs and Medicare Advantage: No delegation necessary
17 Which College Districts Must Report District size Fully-insured Self-insured < 50 full-time employees* Employer reporting does not apply Form 1095-B on all persons who enrolled in coverage >/= 50 fulltime employees* Form 1095-C for each fulltime employee Form 1095-C for each fulltime employee AND Form 1095-C for each employee who was not fulltime but who enrolled in coverage * Including workforce extender (full-time equivalents as defined by ACA)
18 Which College Districts Must Report District size Fully-insured Self-insured < 50 full-time employees* Employer reporting does not apply Form 1095-B on all persons who enrolled in coverage >/= 50 fulltime employees* Form 1095-C for each fulltime employee GBP: HealthSelect only Includes COBRA participants * Including workforce extender (full-time equivalents as defined by ACA) Form 1095-C for each fulltime employee AND Form 1095-C for each employee who was not fulltime but who enrolled in coverage (form) (transmittal) (instructions)
19 Reporting Period Calendar Year
20 Non-Calendar Year Plan Example Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan Feb Mar Apr May Jun July Aug Plan Year Sept Oct Nov Dec Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year
21 Calendar Year Reporting Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan Feb Mar Apr May Jun July Aug Plan Year Sept Oct Nov Dec Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year
22 Reporting Deadlines
23 Reporting Deadlines January 31: statements to employees (February 1 for 2016) Page 3 of instructions: Furnishing Forms 1095-C to Employees
24 Reporting Deadlines February 28: reports to IRS if filing on paper (February 29 for 2016) 28 Page 2 of instructions: When to File
25 Reporting Deadlines March 31: reports to IRS if filing electronically 250+ (1095-Cs): must file electronically <250 (1095-Cs): may file electronically ( encouraged ) 79 Fed. Reg (Mar. 10, 2014)
26 How Reporting Applies to Your College District Recap Reporting is used for employer and individual compliance Large employers file employee reports Absent a delegation to ERS, self-insured employers file enrollment reports Calendar year reporting, beginning with Reports are due early 2016
27 FORM 1095-C Overview Copy to employee Which employees Part I Part II Part III
28 1095-C: Employee Information Voluntary for 2014! (form) (instructions) Page 1 of instructions: Reminders
29 Three Parts Part I Part II Part III
30 1095-C Instructions These instructions are for the employee, not the employer
31 Copy to Employee Paper Mail Last known address OK to mail with W-2 Electronic Consent Specific to 1095-C Delivery Page 3 of instructions: Furnishing Form 1095-C to Employees 79 Fed. Reg (Mar. 10, 2014)
32 HealthSelect/Self-Insured Large Employer No Delegation to ERS Full-time Employees Employees who enroll College district reporting requirement
33 HealthSelect/Self-Insured Large Employer Delegation to ERS Full-time Employees Employees who enroll College district reporting requirement
34 Fully-Insured Large Employer Full-time Employees Employees who enroll College district reporting requirement
35 Full-Time Employee Full-time even one calendar month that reporting year Every full-time, regular employee Every temporary or part-time employee who works 130 or more hours in even one month Page 1 of instructions: Who Must File (first paragraph)
36 Example: Janitor working & -16 academic years Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan Feb Mar Apr May Jun July Aug Plan Year Sept Oct Nov Dec Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year
37 Example: Full-time faculty begins work Fall Sept 2014 Oct 2014 Nov 2014 Dec 2014 X Jan X Feb X X X X X X Mar Apr May Jun July Aug Plan Year Sept Oct Nov Dec Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year
38 Example: Temp works academic year Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan Feb Mar Apr May Jun July Aug Plan Year X Sept X Oct X X Nov Dec Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year
39 Part I Employee and district information Page 6 of instructions: Part I
40 Part II Offer of coverage and cost Pages 6-7 of instructions: Part II Employee O0ffer of Coverage
41 Part II: Three lines Line 14 Line 15 Line 16
42 Line 14 Whether employee and/or family was offered coverage Series 1 codes
43 Line 14 generally meaning the employee was eligible for coverage under the plan Page 7 of instructions: second full paragraph
44 A Series 1 code must be entered for each calendar month, even if the employee was not a full-time employee for one or more months. Page 7 of instructions
45 Series 1 Codes 1A: Qualifying Offer 1B: Offer to employee only 1C: Offer to employee and dependents 1D: Offer to employee and spouse 1E: Offer to employee, spouse, and dependents 1F: Offer of coverage not providing minimum value 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief Page 7 of instructions
46 Series 1 Codes 1A: Qualifying Offer 1B: Offer to employee only 1C: Offer to employee and dependents 1D: Offer to employee and spouse 1E: Offer to employee, spouse, and dependents 1F: Offer of coverage not providing minimum value 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief
47 Series 1 Codes 1A: Qualifying Offer 1B: Offer to employee only 1C: Offer to employee and dependents 1D: Offer to employee and spouse 1E: Offer to employee, spouse, and dependents 1F: Offer of coverage not providing minimum value 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief
48 Series 1 Codes 1A: Qualifying Offer 1E: Offer to employee, spouse, and dependents 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief
49 Series 1 Codes 1A: Qualifying Offer 1E: Offer to employee, spouse, and dependents 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief Enrollee reporting All 12 months
50 Series 1 Codes 1A: Qualifying Offer 1E: Offer to employee, spouse, and dependents 1G: Employee not full-time and enrolled in selfinsured coverage 1H: No offer 1I: Qualifying Offer Transition Relief
51 Line 15 Net cost to employee for lowest-cost, employeeonly coverage.
52 Line 15 Only if code 1B, 1C, 1D, or 1E was checked on Line 14 Page 7 of instructions
53 Line 16 Safe Harbors and other relief series 2 codes Pages 7-8 of instructions
54 Series 2 Codes 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2E: Multiemployer interim rule relief 2F: W-2 safe harbor 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief Page 8 of instructions
55 Series 2 Codes 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2E: Multiemployer interim rule relief 2F: W-2 safe harbor 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
56 Series 2 Codes 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
57 Series 2 Codes: 2C 2C is the most used 2A: Employee not employed on any day Series of the month 2 code 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor -Even if employee was not full-time that month 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief -Even if a safe harbor applies Page 8 of instructions
58 Series 2 Codes: 2A 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
59 Series 2 Codes: 2B 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
60 Series 2 Codes: 2D 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief Pages of instructions
61 Series 2 Codes: 2G and 2H 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
62 Series 2 Codes: 2I 2A: Employee not employed on any day of the month 2B: Employee not a full-time employee for the month and did not enroll in coverage 2C: Employee enrolled in coverage offered 2D: Employee was in a Limited Non-Assessment Period 2G: Federal poverty line safe harbor 2H. Rate of pay safe harbor 2I. Non-calendar year transition relief
63 2I: Non-Calendar Year Transition Relief Employee was not offered affordable coverage for the plan year; AND Employee was offered affordable coverage as of the first day of the - 16 plan year Use 2I for the months of the plan year that fall in Page 8 of instructions
64 Non-Calendar Year Transition Relief: Example Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan Feb Mar Apr May Jun July Aug 2I 2I 2I 2I 2I 2I 2I 2I Plan Year Employee not offered affordable coverage Sept Oct Nov Dec 2C 2C 2C 2C Jan 2016 Feb 2016 Mar 2016 Apr 2016 May 2016 Jun 2016 July 2016 Aug Plan Year Employee offered affordable coverage
65 Recap Part II: Whether employee was offered coverage Cost of coverage Safe harbors and other relief from penalties Enrollee reporting only: Line 14, 1G
66 Part III Only if HealthSelect/selfinsured and no ERS delegation Pages 8-9 of instructions
67 Column a Name of each covered individual
68 Column b SSN s of all covered individuals
69 Column c If dependent SSNs are not available
70 Column d Individual was covered for at least one day in each month of the calendar year
71 Column d (cont.) Check the box(es) for the months in which the individual was covered for at least one day
72 Fully-Insured v. Self-Insured District size Fully-insured Self-insured < 50 full-time Employer reporting Form 1095-B on all persons who employees does not apply enrolled in coverage >/= 50 fulltime employees - Form 1095-C for each full-time employee - Parts I and II only Form 1095-C for each full-time employee - Parts I and II - Part III if employee enrolled in HealthSelect/self-insured coverage AND Form 1095-C for each employee who was not full-time but who enrolled in coverage - Parts I and III (and enter code 1G at line 14 of Part II)
73 Recap Part III is used for enrollment reporting Every employee who enrolled in HealthSelect/self-insured coverage Regardless of whether full-time Do not do enrollment reporting on employees who enrolled in HealthSelect if delegated to ERS or who enrolled in other GBP plans
74 Simplified Reporting Alternative to Form 1095-C Qualifying Offer Method Qualifying Offer Method Transition Relief 98% Offer Method later Pages 5-6 of instructions
75 Qualifying Offer Employee, spouse, and dependents Federal Poverty Line safe harbor Page 11 of instructions
76 Qualifying Offer Employee, spouse, and dependents Net cost to employee of lowest-cost, employeeonly coverage </= 9.5% of FPL for single individual : $11,770 x 9.5% = $1, $1,118.15/12 = $93.18 Federal Poverty Line safe harbor
77 Simplified Reporting District may use simplified reporting with this employee. Did employee receive a QO? NO Was QO for all 12 months of the calendar year? YES YES YES NO Did employee enroll? YES NO NO Is the district self-insured? YES Did district make QO for one or more months of to at least 95% of its full-time employees? NO QOM and QOMTR are optional District must use 1095-C with this employee.
78 FORM 1094-C Overview Transmittal for 1095-C Authoritative transmittal Part II Part III
79 1094-C Page 1 of instructions: Reminders Voluntary for 2014! (form) (instructions)
80 Four Parts Part I Part II
81 Four Parts Part III
82 Four Parts Part Part III IV Part I
83 Transmittal for 1095-C 1095-C 1095-C 1095-C
84 Authoritative Transmittal Aggregate employerlevel data 1095-C 1095-C 1095-C
85 Part I College District information
86 Part II ALE Member Information ALE = Large employer One or more entities that are treated as a single employer under the ACA. 26 C.F.R H 1(a)(5)
87 Line 19: Authoritative Transmittal Indicator AT: check box and complete parts II, III, and IV to the extent applicable Non-AT: leave Part II, lines 20-22, Part III, and Part IV blank Page 4 of instructions: Part II ALE Member Information, Line 19
88 Line 22: Certifications of Eligibility Check each applicable box
89 Certifications of Eligibility Qualifying Offer Method Qualifying Offer Method Transition Relief Section 4980H Transition Relief 98% Offer Method
90 Section 4980H Transition Relief full-time employees* in 2014 One-year delay of shared-responsibility penalties 100+ full-time employees* in 2014 Reduced penalty for failure to offer to at least 70% of full-time employees * Including workforce extender (full-time equivalents as defined by ACA) Page 5 of instructions: Section 4980H Transition Relief; page 13
91 98% Offer Method Affordable coverage All 12 months 98% of employees receiving 1095-Cs Employer does not have to complete Part III, column (b) Page 5 of instructions: 98% Offer Method
92 Part III Only on Authoritative Transmittal
93 Column (a): Substantial Compliance Pages 5 and 12 of instructions
94 Column (b): Full-Time Employee Count 98% Offer Method Page 6 of instructions
95 Column (c): Total Employee Count Page 6 of instructions
96 Total Employee Count (Monthly) Pick one First day of the month Last day of the month First day of the first payroll period Use the same day for every month of the year Last day of the first payroll period Last day of payroll period must fall within calendar month in which payroll period starts
97 Column (d): Aggregate Group Indicator Page 7 of instructions
98 Column (e): Section 4980H Relief Code A or Code B Page 6 of instructions
99 Section 4980H Transition Relief full-time employees* in 2014 One-year delay of shared-responsibility penalties Code A 100+ full-time employees* in 2014 Reduced penalty for failure to offer to at least 70% of full-time employees Code B * Including workforce extender (full-time equivalents as defined by ACA) Page 5 of instructions: Section 4980H Transition Relief; page 13
100 Evaluate Data Systems Which elements do you already track? Which ones do you need to track? What needs to change? Can you automate tracking and reporting?
101 Any Other Questions? colleges.tasb.org
102 Affordable Care Act Reporting Requirements Amy Magee Senior Attorney for Community Colleges Texas Association of School Boards. Texas Association of School Boards, Inc. All rights reserved.
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