affordable care act reporting and filing. agenda review of the affordable care act individual vs....
TRANSCRIPT
Agenda
• Review of the Affordable Care Act• Individual vs. employer mandate• Required IRS filings for employers• How Paycor helps.
Review of the Affordable Care ActACA was designed to ensure that Americans have health insurance
• Individuals can obtain insurance two ways:1. Through the Marketplace (tax credits are available for
those who can’t afford it)
2. Through their employer if they work 30 hours or more weekly.
Review of the Affordable Care ActThe IRS needs accountability from employers that they are complying with the law• They want to know…
• Who has coverage• What kind of coverage they have• Where did they get it
The IRS wants to make sure employers who are supposed to be providing coverage are doing so—if not, they can be penalized.
Required IRS filings
• ACA added two new reporting and filing requirements related to health insurance coverage:• Section 6055 deals with
the individual mandate• Section 6056 deals with
the employer mandate.
Section 6055 & the Individual Mandate
•Beginning in 2014, PPACA requires all non-exempt individuals to either maintain minimum essential coverage (“MEC”) or pay a penalty as part of their income tax returns for every month they go without MEC
•Section 6055 reporting is necessary to determine whether individuals are maintaining MEC
•Returns must be filed with the IRS and statements furnished to covered individuals.
Section 6056 & the Employer Mandate
•Requires applicable large employers to file returns with the IRS and provide statements to full-time employees about the health insurance coverage offered
•Information used to determine if the employer has complied with the Employer Shared Responsibility mandate and to determine if individual is eligible for premium assistance.
Applies to all Applicable Large Employers
Required IRS filings overviewReporting Who Reports Transmittal Form Deadline Paycor
Filing?
6055 Small Employer with Self-Insured Plan
1094-B 1095-B 1/31 of each year (2/1/16)
No
6055 Small ER with Fully Insured Plan-Insurer
1094-B 1095-B 1/31 of each year (2/1/16)
No
6056 Large Employer with Fully Insured Plan
1094-C 1095-C 2/28 (or 3/31 if filed electronically*)
Yes
6055/6056 Large Employer with Self-Insured Plan
1094-C 1095-C 2/28 (or 3/31 if filed electronically*)
Yes
*Must file electronically if providing 250 or more “returns”
Penalties for not filing• Penalties range from $30-$100 per return
• Up to maximum of $1.5 million under Sections 6721 and 6722
• Special relief for 2015: no penalties will be imposed as long as the filing entity makes a good faith effort to comply
• However, you don’t want to invite the IRS into your business.
Form 1095-C: Part I
Information about both the employee and employer Static payroll/benefit admin
dataLines 7-13: Employer information
Comes from client.
Lines 1-6: Employee information including SSN
Line 10: Contact telephone number who the recipient may call about the information reported
Static payroll/benefit admin data
Form 1095-C: Part II
Client/benefit admin
Client/benefit admin
Client/benefit admin.
Line 15: Report the amount of the employee’s share of the lowest cost monthly premium for self-only coverage
Line 14: Offer of Coverage, for each month enter a “Series 1” code from the instructions
Line 16: Safe Harbor Codes, for each month enter a “Series 2” code from the instructions
Information required•All Applicable Large Employers (self-funded or fully-insured)• Line 14 Code Series 1 (Offer of coverage codes)
CODE DESCRIPTION HOW COMMON
1A MV offered at less than 9.5% of FPL ($93.18/mo) Common
1B Offer to EE only Rare
1C Offer to EE + Dependent (not spouse) Rare
1D Offer to EE + Spouse (non dependent) Rare
1E MV offered to EE, at least MEC offered to spouse & deps Common
1F MEC that is not MV offered to employee Some
1G Self-funded offered to part-time EE Rare
1H No offer of coverage Common
1I No offer to employee but employer using qualifying offer relief ?
Information required•All Applicable Large Employers (self-funded or fully-insured)
• Line 16 Code Series 2 (safe harbor codes)
CODE DESCRIPTION
2A Not employed any day that month
2B Part-time or termination month when not covered all month
2C Enrolled in coverage (Use over any other code if applicable)
2D EE in non-assessment period (e.g. waiting period)
2E Multi-employer plan interim relief
2F W-2 Safe harbor
2G FPL safe-harbor
2H Rate of pay safe harbor
2I Non-calendar year plan employer transition relief
Form 1095-C: Part III
•This section only applies to organizations with self-insured plans
Data comes from benefit admin.
Fully insured plan employers do not
complete Part III
Form 1094-C: Part I
Attach all 1095-C filings to this transmittal form:
Lines 1-6: Employer information
Lines 7-8: Contact information for individual responsible for addressing IRS questions about the formLines 9-16: Employer Information
Line 17: Reserved line for IRS use
Line 18: Total number of 1095-Cs submitted.
Comes from payroll/benefit admin
Comes from client
Comes from benefit admin
????
Derived number of 1095-Cs generated from system used for filing
Form 1094-C: Part II
Lines 19-21: For filings where there are related employers and where each is filing for their own group
Line 22: If an employer files under one of the four optional filing methods, the filer discloses which method they are using
Comes from client
Comes from client/benefit admin.
Line 22: Special Reporting RulesQualifying Offer•Employer offers MV coverage with employee cost less than 9.5% of FPL ($93.18 in 2015)•Benefits to employer:
• Enter code 1A in line 14 of 1095 and employer does not have to provide cost of lowest cost plan on line 15
• Can provide a simplified statement to employees instead of a copy of the 1095
•Problem with the simplified statement approach• Employer still has to provide a 1095 to the IRS…why not just
give the employees a copy• Self-funded employers cannot use the simplified statement for
anyone who has elected coverage.
Line 22: Special Reporting Rules98% Offer•Employer offers affordable MV coverage to 98% of full time employees•Benefits to employer:• Employer does not have to provide number of
full-time employees by month in column (b) of 1094.
Form 1094-C: Parts III and IV
Comes from insurer
Comes from payroll (Paycor’s ALE report)
Comes from payroll (Paycor’s ALE report)
Comes from benefit admin/client.
Comes from benefit admin/client
Comes from benefit admin/client
Column (a): Did employer offer coverage to 95% of full-time?Column (b): Number of full-time employees
Column (c): Total number of employees
Column (d): Is employer part of a controlled group?
Column (e): Transition relief code• Code A for 50-99 FTE relief• Code B for all other 100+ transition relief
Lines 36-65: Names and EINS of other ALE Members of the Aggregated ALE Group (if applicable)
What is Paycor doing to help?• Products that can help
• Benefits administration tool• Time and attendance tracking• Reporting & Analytics: ACA reporting to help you
determine ALE status, employee eligibility and plan affordability
• Filing assistance for 1095-C and 1094-C• We will aggregate information from our systems• Clients that are not using Paycor’s benefit
administration or time and attendance system can import or enter information through a client portal for an additional fee
• We will file the 1094-C and 1095-C forms on the client’s behalf.
PricingPrice:
•Chargeable service with additional fees for aggregating the data in our portal and for filing the 1094-C and 1095-C with the IRS.
Summary: Next Steps
1. Learn the fundamentals- Review the returns and instructions
2. Determine which reporting requirements and forms apply to your organization
3. Determine what information you are required to collect and where you’re going to get it, and start collecting it on a monthly basis
4. Develop a game plan to get information into the system and to handle the filing
5. Communicate with employees.