ACA Reporting Requirements: Be Prepared for What s Next

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1 ACA Reporting Requirements: Be Prepared for What s Next September 24, 2014 Dwaine Sohnholz Director Business Analysis & Project Management Sara Suing Manager - Education 407 S 27 Avenue Omaha, NE sales@teamsoftware.com

2 Agenda ACA Reporting & IRS Forms 1095-C: W-2 Equivalent for Healthcare 1094-C: Transmittal cover/summary Review information needed and detailed IRS codes 1095-C Update on TEAM s Insurance Benefits Module 2 Material in this webinar is not intended as legal, financial or tax advice. Please consult your attorney, financial or tax professional to determine the best plan for your company.

3 Two Key IRS Forms For Employers subject to the ACA shared responsibility mandate In accordance with Internal Revenue Code Section 6056 Used to determine employer payments under section 4980H (penalties) 1095-C: Employer-Provided Health Insurance Offer and Coverage 1094-C: Transmittal of Employer-Provided Health insurance Offer and Coverage Information Returns 3

4 Two Key IRS Forms (continued) In General Timing: t Required for C Separate form required for each person who was a full-time employee for any month of the calendar year Can be included with W-2 s Must be filed on or before January 31 following the calendar year of coverage January 31, 2016 is the first deadline Electronic filing will be required for employers with more than 250 statements Procedural guidance from the IRS is pending. Software Developers and Transmitters will look for Publication 5165 later this year C (Transmittal) One authoritative transmittal per employer with aggregate employee data for all full-time employees

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6 C Part 2 Offer & Coverage Codes Line 14: 9 Different Codes possible for each of 12 calendar months! Did you offer Minimum Essential Coverage? If not, for 2015, was there ACA transition relief from requirements? Did the MEC offer provide Minimum Value? Do you use an affordability safe harbor? Who was offered coverage? What combination of employee, spouse, dependents? Do you (employer) provide coverage through a self-insured plan?

7 1095-C Part 2 Offer & Coverage Codes For Full-Time Employees Minimum Essential Coverage (MEC)? Affordable: <= MEC offered to Provides Minimum 9.5% of mainland Spouse & Value (MV)? FPL? Dependents? 14 Code: 1A MEC offered to Employee Only? 14 Code: 1B MEC offered to Employee and dependent(s) [not spouse] 14 Code: 1C MEC offered to Employee and spouse [not dependents] 14 Code: 1D (see next page) 1 2 MEC offered to Spouse & Dependents? 14 Code: 1E 7

8 1095-C Part 3 Offer & Coverage Codes 1 2 (see previous page) (continued) (Does not provide MV) 14 Code: 1F Offer of MEC Transition Relief 2015? 14 Code: 1H 14 Code: 1I If employer is self-insured: For any employee who enrolled; but was NOT a fulltime employee for any month of the calendar year: Offer to EE not FT, & enrolled in self-insured coverage for 1+ months 14 Code: 1G 8

9 Questions So Far? 9

10 Line 15 Complete this only if coverage offered to the employee provided minimum value, and Line 14 code entered was 1B, 1C, 1D, or 1E (The Federal Poverty Line safe harbor wasn t used, and the coverage offered, providing MV, was for any combination of employee, spouse & dependents) 10

11 Question for Participants (instant poll) What is the best monthly premium (carrier cost) you ve found for the lowest cost, employee-only coverage that provides Minimum Essential Coverage (MEC) and Minimum Value (MV)? a) Under $150 b) Between $150 and $249 c) Between $250 and $349 d) Between $350 and $449 e) $450 or more 11

12 Line 16: 9 More Codes! And an option to leave it blank (which means a penalty probably applies) 12

13 1095-C Part 2: Line 16 Codes Employed on ANY day of the month? 16 Code: 2A (t employed during the month) Full time employee for the month? 16 Code: 2B (t full time & did not enroll) t Yet Enrolled in MEC Offered 16 Code: 2C (enrolled in MEC) a b (see next page) 13

14 1095-C Part 2: Line 16 Codes (continued from previous page not full time yet, or not enrolled in coverage) * An employer is treated as offering health coverage to an employee if the employer is required by a collective bargaining agreement or related participation agreement to make contributions for that employee to a multiemployer plan that offers, to individuals who satisfy the plan s eligibility conditions, health coverage that is affordable and provides minimum value, and that also offers health coverage to those individuals dependents. Limited-n Assessment Period (e.g. Initial Measurement) Employer eligible for multiemployer interim rule relief* W-2 Safe Harbor Used Federal Poverty Line Safe Harbor Used 16 Code: 2D (in initial measurement period) 16 Code: 2E 16 Code: 2F 16 Code: 2G Rate of Pay Safe Harbor Used 16 Code: 2H n-calendar year transition relief 16 Code: 2I 14 OR codes apply Then 16 Code: Leave blank. Take penalty.

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19 Question for Participants (instant poll) What stage of ACA preparation best describes your organization today? a) Just Beginning: Collecting information and setting policy direction b) Punting: We re Outsourcing to a Third Party c) Actively Preparing: We re executing our plans WinTeam setup, etc. d) Ready as Can Be: We re in good shape and are prepared for January 1,

20 References IRS Draft Form 1095-C IRS Draft Form 1094-C (Transmittal) IRS Draft Instructions for 1094-C & 1095-C 20

21 Recap Form 1095-C The W-2 equivalent on healthcare reporting for each full-time employee File by 1/31/16 for coverage year 2015 Form 1094-C Summary & transmittal cover to IRS File by 2/28/16, or 3/31/16 if done electronically 21

22 Recap What s TEAM doing? We have the foundational information covered in the Insurance Benefits Module. Need to ensure we have all the right data captured before 1/1/15 starts. Current plans are to address & release in December. 22

23 Implementation Planning How do you know if you are prepared to implement Insurance Benefits in WinTeam? Determine your Eligibility Rules. Measurement Periods and Stability Periods Minimum Hours of Service Requirements Select your plans with your provider and all pricing decisions completed. Determine which plans will be offered to each group of employees. Consider what groups of employees have different rules for pricing, offering or eligibility. Review your Employee Master File to ensure all employees are assigned appropriately for the following fields: Employee Title, Classification and Type fields Full Time/Part Time status Hourly/Salary status 23

24 Implementation Planning Are you ready for 1/1/15? Please contact our Education Department to schedule your training as soon as possible. Please plan in advance for scheduling purposes. Even if you will not be ready until v 1 st, please contact us now to secure your timeslot on our calendar. Plan for a minimum of 2-4 hours, however depending on how many benefits you will need to set up it could take 6-8 hours. Our contact information: training@teamsoftware.com 24

25 Thank you for joining us! Check our blog for the link to the slides and recorded webinar. 407 S 27 Avenue Omaha, NE sales@teamsoftware.com