Designation of TRS for the IRC Section 6055 Reporting (Affordable Care Act) TRS-Active Care Districts/Charters

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1 Designation of TRS for the IRC Section 6055 Reporting (Affordable Care Act) TRS-Active Care Districts/Charters Region One Education Service Center Finance Advisory Council October 16, 2015

2 General Information Who can participate? School District or Charter that participates in TRS-ActiveCare (Health Insurance) What? elect to designate TRS as its designated governmental unit to fulfill the reporting requirements under IRC Section 6055 for its active employees and COBRA qualified beneficiaries (and their dependents) who are enrolled in one of the PPO plans TRS-ActiveCare 1-HD, TRS-ActiveCare Select TRS-ActiveCare 2 When for the months of enrollment during the 2015 calendar year. Deadline is November 1, 2015 to submit form

3 Non Applicable Large Employer (ALE) Non-ALE s - those employers that are not an Applicable Large Employer are required to only satisfy IRC Section 6055 reporting obligations; they do not have to comply with the IRC Section 6056 reporting requirements. can delegate to TRS all of their reporting obligations concerning employer plan information that arises under the Patient Protection and Affordable Care Act (PPACA) for those individuals enrolled in one of the PPO plans offered under TRS- ActiveCare TRS will not be responsible for any reporting obligations under IRC Section 6055 concerning the months of the 2015 calendar year when the non- ALE's active employees and COBRA qualified beneficiaries (and their dependents) are not enrolled in one of the PPO plans available through TRS-ActiveCare.

4 Applicable Large Employers (ALE s) ALEs: ALEs (Applicable Large Employers) are required to satisfy both IRC Section 6055 reporting obligations as well as IRC Section 6056 reporting obligations. A designation of TRS relates only to the reporting obligations under IRC Section 6055 for those individuals enrolled in one of the PPO plans offered under TRS-ActiveCare, for only the months of enrollment during the 2015 calendar year. TRS will not be responsible for any reporting obligations under IRC Section 6055 concerning the months of the 2015 calendar year when the ALE's active employees and COBRA qualified beneficiaries (and their dependents) are not enrolled in one of the PPO plans available through TRS-ActiveCare. Also, ALEs will remain responsible for any and all reporting obligations applicable to the ALE under IRC Section 6056.

5 Options ALEs may choose from several different approaches with regard to its active employees and COBRA qualified beneficiaries (and their dependents) who are enrolled in one of the PPO plans offered under TRS- ActiveCare, for the months of enrollment during the 2015 calendar year: designate TRS to fulfill the reporting requirements under IRC Section 6055 (Form 1094-B and Form 1095-B); the ALE will remain responsible for filing the Section 6056 forms (Form 1094-C and Parts I and II only of Form 1095-C) not designate TRS to fulfill any of the reporting requirements under IRC Section The ALE could then choose one of two approaches to satisfying the reporting obligations under IRC Sections 6055 and 6056: (1) file Form 1094-B and Form 1095-B, along with Form 1094-C and Parts I and II only of Form C; or (2) file Form 1094-C and Parts I, II and III of Form 1095-C.

6 HMO s HMOS associated with TRS-ActiveCare: For only the months of enrollment during the 2015 calendar year, the HMOs themselves are responsible for reporting active employees and COBRA qualified beneficiaries (and their dependents) who are enrolled in plans offered by the HMO.

7 Steps Required to Designate TRS Designation Form To be effective for the 2015 calendar year IRC Section 6055 reporting obligation, complete, execute, and return to TRS, at the address noted therein, a completed and unaltered Designation of Reporting Responsibilities Under Internal Revenue Code Section 6055 (the "TRS Designation Form") on or before November 1, An altered TRS Designation Form will not be accepted by TRS. An unaltered TRS Designation Form received after this date will not be accepted by TRS.

8 Steps Required to Designate TRS Well Systems Contract To be effective for the 2015 calendar year IRC Section 6055 reporting obligation, complete, execute, and return to WellSystems, at the address noted therein, a completed and unaltered Contract for Services between WellSystems, LLC and the Participating Entity Concerning IRC Section 6055 Reporting Obligations (the "WellSystems Contract") on or before November 1, An altered WellSystems Contract will not be accepted by WellSytems. An unaltered WellSystems Contract received after this date will not be accepted by WellSystems.

9 Steps Required to Designate TRS Social Security Numbers The Social Security Numbers of the following individuals are required to be reported to WellSystems on or before November 1, 2015 for the 2015 calendar year being reported: each active employee and dependent of an active employee) who was enrolled in a PPO plan offered under TRS-ActiveCare ( even for only one month) during the 2015 calendar year. If the Participating Entity is unable to obtain the Social Security Numbers of one or more of the above noted individuals, after making the reasonable efforts required by the Internal Revenue Service, the Participating Entity shall obtain the dates of birth of such individuals and provide such dates of birth to WellSystems on or before November 1, 2015 for the 2015 calendar year being reported.

10 Contact Information Contact Information: For further information, please contact your Enrollment Coordinator at WellSystems.

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