implementing the affordable care act in 2015 spring conference/presentations/ed joh… ·...

Implementing the Affordable Care Act in 2015

May 20, 2015

Today’s Speakers

R. Edward Johnson, ASA, MAAA, ACA

Senior Vice President, Consulting Actuary

SHDR/BB&T Insurance Services

Edward Johnson is a Consulting Actuary with Stanley, Hunt, DuPree, & Rhine (SHDR), a division of BB&T Insurance. His focus is on Healthcare, including the ACA, in the Consulting and Actuarial Services department. Edward has over 16 years of experience working primarily as a Healthcare actuary, most recently as a consulting actuary with SHDR.

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R. Edward Johnson

Guidance and interpretations relating to these matters are being released on a regular basis. BB&T Insurance Services is not providing legal or tax advice. To ensure compliance with requirements imposed by the IRS, any discussion of U.S. tax matters contained in this communication (including any attachments) is not intended and cannot be used by anyone to avoid IRS penalties. This material is for informational purposes only.

Disclaimer

• Before we get started – May 20, 2015

• Our presentations provide general information. This is not legal advice.

• Guidance on many provisions of the Patient Protection and Affordable Care Act (PPACA or ACA) are outstanding. New guidance may be issued regarding PPACA, or more generally, changes to statutes, rules, or regulations may be forthcoming that change the content of this presentation or alter the answers to some questions. Keep this in mind as you review any recordings.

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What We Will Cover Today

• ACA –The Ever-Changing Landscape

• What’s New – Latest Guidance

• Employer Shared Responsibility – Review the Basics

• Employer Reporting Requirements

• What Employers Can Do Now

• Q & A

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2015 – Changing Landscape – Twists and Turns

Changes to the Changes – ACA

Still one of the biggest HR challenges in 2015.

Future is still clouded with uncertainty.

New Republican Majority urging major revisions to the ACA.

Employer mandate, closely followed by the Employer Reporting requirements.

Another Supreme Court case threatening to undermine major part of the law.

Affordable Care Act : Key Dates

6

March Supreme Court

to hear oral arguments ACA

subsidies

June SCOTUS Rulings

January Start of

Collection of 6055 & 6056

Data Questions regarding eligibility

January 15th Deadline to pay 1st TRF payment

New Federal Poverty Line

Released

W2 reporting for employers with more than 250

W2s filed. Box 12, DD 2015 OOPM $6,600 self

$13,200 HDHP OOPM

$6400/$12900

August MLR checks

issued by carriers in Fully Insured market

July July 31st PCORI

Due for self

funded $2.08

September New SBC to be issued by

Sept 15

October

New Proposed Open

Enrollment in Marketplace

begins ( Oct 1 )

November November 15

deadline to pay 2nd TRF payment

December

Open Enrollment ends

December 15

April Supreme

Court to hear same-sex marriage

Delays : Unknown Start Dates Final IRS forms 1094-C, 1095-C 2015 HPID Auto Enrollment 105 H non-discrimination fully insured Pending Implementation Cadillac Tax -- 2018

2015 – What We Are Watching - The Courts

• The Supreme Court heard 84 minutes of oral arguments … King v. Burwell on March 4, 2015

• The case concerns tax subsidies that are central to the operation of the ACA. According to the challengers, those subsidies are not available in the 34 states that have decided not to run their own marketplace / exchanges.

• If the challenges are right, millions of people receiving subsidies would be ineligible, destabilizing and perhaps dooming the law. Employers would avoid the employer shared responsibility provisions in these States; individual mandate is impacted as well.

• Balance Constitutional role of States vs human and social loss

• Matter of statutory authority, not constitutional authority, unlikely whole law to be struck down.

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Source CIAB and Mintz Levin, “On Verge of Meltdown”

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2015 – Changing Landscape

ACA issues we are watching

Washington Remains Fractured

Small signs of Bipartisan Cooperation

• 40 hour work week

• Possible 2 year delay expansion small group market to up to 100 /rating rules

• Wellness – and EEOC – proposed

• Fixes after Burwell Decision this summer

• Possible repeal Cadillac tax

Cadillac Tax ~ 4980 I – 2018

• For tax years beginning in 2018, annual limit threshold will be:

– $10,200 individual

– $27,500 family

• A non-deductible 40% excise tax will be imposed on insurance companies, employers, and/or plans for amounts exceeding the threshold to include:

– Aggregate cost of employee premiums (COBRA equivalents)

– Takes into account pre-tax premiums and reimbursements from FSA, HRA, and contributions to HSA or medical savings accounts

– Applies to self-funded and fully insured; will be reported on W-2

– 60% of employers surveyed expect to trigger tax if they don’t adjust plans (Towers Watson study Nov 2013)

• IRS Notice 2015-16– Feb 23, 2015 --- issued 25 page memo asking for comments – determining cost coverage of SF plans, HRAs, on-site clinics…all to consider incorporating into final regulations

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Source: Zywave

Employer Shared Responsibility – Review

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Employer Mandate Basics

Employers must offer medical coverage (“minimum essential coverage” ) that meets certain standards to FTEs and their dependent children up to age 26.

Employer Size Effective for plans beginning in 2015

2016 plan year and beyond

50 -99 full-time employees Does NOT apply ( if certain requirements met)

Employers must offer coverage to 95% of FTEs

100 or more full-time employees



Source: IRS ESR final regs., Groom Law Group

ALE ( Applicable Large Employer) Determination: Example

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2014 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Full-Time (FT) Employees 48 40 40 40 41 40 39 62 63 60 61 55

Full-Time Equivalents (FTE)

Hours paid: non-FT employee 1 120 120 0 0 0 0 0 60 70 120 90 95




Total Hours Paid to non-FT employees 275 120 0 0 0 0 0 190 345 420 360 390

Total FTEs (Total Hours/120) 2.29 1.00 0 0 0 0 0 1.58 2.88 3.50 3.00 3.25

Employer Size (monthly) 50.29 41.00 40.00 40.00 41.00 40.00 39.00 63.58 65.88 63.50 64.00 58.25

Employer Size (for all months) 606.50

Average Employer Size/Month 50.54

Employer Size (Rounded) 50

For this calculation only, use maximum value of 120

hours per non-FT employee

Qs 4, 5, 12

2015 TRANSITIONAL RELIEF: Employers can use any six

consecutive months in 2014 to determine ALE status

Determining Applicable Large Employer (ALE) Status

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Source : Zywave Jan 20

• Groups of 1-49 – Not subject Employer Mandate

• ALE status determined by looking at FT and FTE

employee count from prior year

• Make sure you check each year.

• Aggregation rules and

seasonal worker

exception still apply

An ALE Meets Employer Shared Responsibility Mandate If:

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• Coverage is offered to: – At least 70% in 2015 of full-time employees and their children under

age 26 – phasing up to 95% in 2016. Spouses are not dependents.

9.5%

60%

• An employer’s coverage is affordable if: – The employee’s share of the premium for self-only coverage is 9.5% or

less of household income

– Safe harbor affordability computations can be:

1. 9.5 percent of the employee’s W-2 wages

2. The employee rate of pay per month (hourly rate x 130 or monthly

salary), or

3. FPL = Federal Poverty Level for a single individual

• An employer offers coverage with minimum value if: – The proportion of cost of covered services paid by the plan is at least

60% of the expected cost for a standard population

95% in 2016

70% in 2015

Qs 19, 20 ,22, 34, 38 & 39

* Penalties are calculated and assessed monthly ($2,000 will be $166.67/month,

$3,000 is $250/month). The maximum penalty is the lesser of the two penalties.

Penalties are expected to increase each year by the growth in insurance premiums.

Employer Mandate – Pay or Play 2015 (100+)

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P A Y

Does the insurance pay more than 60% of covered health care

expenses? AND Do all full-time employees pay less than 9.5% of income for

coverage? And offer to 100% of all FT

employees

Does the employer offer MEC coverage to 70% of all full-time employees in 2015?

95% in 2016?

Do any full-time employees obtain

subsidized coverage on an Exchange?

No penalty for

small employers

YES

YES

YES

Do any full-time employees obtain

subsidized coverage on an Exchange

NO

$3,000 PENALTY

“unaffordable”

YES

Start

Recheck Monthly

$2,000 PENALTY “No offer” coverage

Does the employer have at least 100 full-

time equivalent employees in 2015?

50 in 2016

Total Penalty* = $2,000 x (full-time EE count - 30)

2015 only - 80

Total Penalty* = $3,000 x each full-time employee receiving

subsidized Exchange coverage

YES

Full-time = 30 or more hours/week

Full-time equivalents =

full-time employees + (all part-time

hours/120)

No penalty as affordable

coverage is offered

NO

Recheck Monthly

NO

P L A Y IRC §4980H(a) IRC §4980H(b)

Qs 18, 24, 25

Source:, Employer Shared Responsibility Provisions

under ACA, Department of the Treasury, Feb. 10, 2014

Know Which Employees You Have

What kind of employee is each worker?

• Full-Time Benefit-Eligible = 30 hours of service

• Variable-Hour: Not reasonably expected to work on average at least 30 hours per week, uncertain or fluctuating hours

• Seasonal: For six months or less (p 57)

– Ski instructors

– Golf course workers

– Resort and hospitality

• Part-Time – Less than 30 hours, set/certain hours (e.g., will only ever work 25 hours)

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Full-Time Status Determination = 130 Hours per Month

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YES

YES

Unknown? Unknowable?

NO

NEW employee

is hired Offer coverage

(within 90 days)

Measure hours over Initial Measurement

Period

Did the employee average 130+/mo?

Offer coverage for stability period or potentially pay a penalty

No offer of coverage is required

Is employee expected to be full-

time?

(130 hrs+ / month)

Count all hours of service =

Hours worked + Hours for which payment is due including:

- Vacation

- Holidays

- Illness

- Incapacity (including

disability)

- Layoff

- Jury duty

- Military duty

- Leave of absence

Source:, Employer Shared Responsibility Provisions under ACA, Department of the Treasury,

Feb. 10, 2014

Ad

min

. P

eri

od

Example: Calendar-Year Plan

2013 2014 2015

A S O N D J F M A M J J A S O N D J F M A M J J A S O N D

Standard Measurement Period 12 months

Admin. Period

Standard Stability Period 12 months

Initial Measurement Period 12 months

Initial Stability Period 12 months

April ‘14 Variable-Hour

New Hire

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Stability Period

Admin. Period

Standard Measurement Period 12 months

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Employer’s Ongoing Standard Measurement Period’s range is 10/15/15-10/14/16.

Assume Paula begins working 30 hours during the 10/15/15-10/14/16 Standard Measurement Period

Paula’s optional Administrative Period cannot be longer than the last day of the first calendar month beginning on or after the 1-year anniversary of the employee's start date

Paula’s Limited Stability Period: Because she did not average 30 hours during IMP, she is treated as Part-time

Paula is not offered coverage from the start date (5/10/15) through all of 2016

Paula’s Initial Measurement Period is 12 months

Assume Employer hired Paula as a variable hour Employee on 05/10/15. Paula averages 29.9 hours at the start, but halfway through the Initial Measurement Period (IMP) she averages 30 hours.

Employer offers plan coverage to Employee effective 1/1/17-12/31/17

Assume Susan ‘s hours remain variable during the 10/15/15-10/14/16 Standard Measurement Period

Employer’s Ongoing Standard Measurement Period’s range is 10/15/15-10/14/16.

Susan is not offered coverage from the start date (5/10/15) employer is tracking hours in IMP

Susan’s optional Administrative Period cannot be longer than the last day of the first calendar month beginning on or after the 1-year anniversary of the employee's start date

Susan’s Initial Measurement Period is 12 months

Susan’s Stability Period: Because she did not average 30 hrs. during IMP, she is treated as Part-time ; no offer of coverage

Employer’s Administrative Period (which runs from 10/15/16 -12/31/16)

Susan is "classified" as a full-time Employee for the 2017 Stability Period, and must be offered coverage.

Susan receives another chance to qualify for full-time status. Employer must count the hours in the SMP Susan worked from 10/15/15-10/14/16

Assume Employer hired Susan as a variable hour Employee on 05/10/15. Susan averages 26 hours at the start and hours continue to fluctuate through the Initial Measurement Period (IMP).

Begins 5/9/16

Begins no later than 7/1/16

VHE Look Back MP: IMP PT – then to Full Time during Standard MP

Source : Florida Blue 2015

Employer Reporting Requirements

ACA Reporting

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Provision: Employer reporting on

value of health coverage

Employer requirement

to inform employees of

coverage options

Reporting of enrollment

in health insurance

coverage

Reporting of employer

offer of minimum

essential coverage

Applies to: Employers who issue at

least 250 W2 forms

annually

Employers subject to

the Fair Labor

Standards Act

Self-Insured employers,

insurers

Large Employers, ALEs

Submit to: IRS Employees IRS IRS

Effective: 1/31/2013 3/1/2013

Existence of Exchanges

1/1/2015*

§ 6055

Forms 1094 B, 1095 B

1/1/2015*

§ 6056

1094 C,1095 C

Employer Reporting Requirements

• To be reported in 2016 for all plan years starting after 12/31/14

Generally ONLY Groups 50+

Unless SF under 50

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2015 – Employers Prepared??

Changes to the Changes – ACA

• Only 51% of employers with at least 1,000 workers said they are ready to handle the health care reporting per an ADP survey.

• 38% said they were ready for health exchange notice management and 40% for penalty management.

• HR, payroll and finance and tax reporting all involved

• Integrate data on employee eligibility, FTE calculations, counting hours including new data elements like FMLA, jury duty, military leave, other absences.

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Section 6055 and 6056 Reporting –

Reporting rules apply to:

• Providers of minimum essential coverage (6055) including self funded employers

• Applicable large employers (6056): 50 + ALEs

Reporting entities must:

• File information returns with the IRS

• Provide statements to either full-time employees (6056) or

• Provide statements to covered individuals (6055)

Purpose of reporting:

• Help IRS administer employer and individual shared responsibility rules

• Determine whether an employee is eligible for a premium tax credit for Exchange coverage

• Show compliance with the individual mandate

Self-funded plan sponsors that are ALEs must report under both sections, but will use a combined reporting method

Source : Zywave Jan 20, 2015

A, B, Cs

• Form 1095 A is a tax form sent to consumers enrolled in health insurance in the Public Exchanges in 2015

• Employees will need to file along with form 1040 and form 8962 for the Premium tax credit ( federal subsidy)

•B forms – generally Insurers and Non ALEs Self funded

•C forms – ALEs over 50 (self funded

must complete Part III of 1095C for any employee enrolling or Form B for non-employees enrolled ie; COBRA, retirees, etc.)

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Reporting Deadlines

• Rules effective for 2015 coverage – 2015 coverage information will be reported in 2016

– Employers must collect information during 2015

• Annual deadlines: – Individual statements due

by Jan. 31

– IRS returns due by Feb. 28 (March 31 if filed electronically)

• 2016 dates: – Employee statements: Feb. 1

– IRS returns: due Feb. 29 (March 31 for electronic filing)


Employer Reporting Distribution

• Final 2014 version released and instructions on Feb 8

• Distribution: 1095 C :Paper – US mail ( may distribute with the Employees W2)

– Hand delivery or intra-office mail may not satisfy delivery requirements

• Electronic: Employees must Opt In. Posting to a website , employees must be separately notified. Having an electronic opt-in for other electronic forms does NOT equal an opt-in for

electronic delivery of the 1095C employee statements.

• Data Collection: Only the SS# of the FT EE is reported by ALE

• Self Funded plans (and Insurers) need to make “reasonable attempts” of outreach ( defined as three) to obtain SSN/TIN of each employee or subscriber or their dependents whose SSN/TIN you don’t have. If you still don’t have after three attempts, you may use date of birth for any of those covered individuals

Source: Zywave, Thompson Reuters

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Section 6056 : ALE Required Returns

Form 1094-C: Transmittal


2014 final instructions available

Form 1095-C: Offer & Coverage

1094-C Transmittal (6056 Employer ALE reporting)

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Lines 9-16 Used only when a Designated

Governmental Entity (DGE) ALE

member

Lines 1- 8 General ALE info- name, address, EIN, etc.


29

Line 18 – Total number of forms 1095-Cs submitted along with this transmittal form 1094-C


30

Part II – ALE member Information , Lines 19-20 Authoritative Transmittal Line 21 Is ALE member of aggregated Group? If NO, do not complete Part IV


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Line 22 – select all that apply

Line 22 box C –check if either (1) 2015 50-99 transition relief or (2) Minus 80 (or 30 in

2016) relief

Reporting Basics: Determine if “simplified” Offer Methods A, B or D make sense for your organization. Self funded plans read instructions, may not apply.

1094-C Transmittal Part III

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Part III --- Column A – MEC Offer check YES on line 23 if coverage was offered to at

least 95% of FTEs and dependents for the entire calendar year. If not, mark boxes on lines 24-35 per month. Also check YES on line 23 if employer did not offer to at least 95% of FTEs and dependents BUT is eligible for transition relief ( e.g., 70% for 2015)


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Column B Enter the number of FTEs for each month. Do not include any employees in a Limited Non-Assessment Period. If checked 98% offer method, on line 22, it is not required to complete column (b)


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Column C Enter the TOTAL number of employees for each calendar month. FTE, non FTE and in limited non – assessment period. Choose the first day of each month or the last day of each month consistently. Can use first or last day of payroll that starts during the month


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Column D Aggregated Group Indicator if YES on Line 21 Complete Part IV listing Name , EIN each member in the Aggregated ALE Group


Codes for Section 4980H Transition Relief Indicator -- Form 1094-C Part III, Column (e)

A. 50-99 Transition Relief (ALEs with fewer than 100 full-time employees)

B.100 or more Transition Relief (ALEs with 100 or more full-time employees = Minus 80 or Minus 30 in 2016)

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Column E Enter Code A or B for Transition Relief A= 50-99 B= 100 ALE minus 80

1094-C Transmittal : Part IV Aggregated ALE

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1095-C – Offer and Coverage

38

Part I – ALE Employee Info – Lines 1-13 Report information on each employee

Reporting Basics: Must report for any employee who was FT for at least 1 month in the year.


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Part II List IRS Indicator Codes Line 14 – Offer of Coverage Line 16 – 4980 H Safe Harbor

1095-C Indicator Codes

1095-C Line 14: Offer of Coverage

1A. Qualified Offer: Minimum Essential Coverage providing Minimum Value offered to full-time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and Minimum Essential Coverage offered to spouse and dependent(s).

1B. Minimum Essential Coverage providing Minimum Value offered to employee only.

1C. Minimum Essential Coverage providing Minimum Value offered to employee and at least Minimum Essential Coverage offered to dependent(s) (not spouse).

1D. Minimum Essential Coverage providing Minimum Value offered to employee and at least Minimum Essential Coverage offered to spouse (not dependent(s)).

1E. Minimum Essential Coverage providing Minimum Value offered to employee and at least Minimum Essential Coverage offered to dependent(s) and spouse.

1F. Minimum Essential Coverage not providing Minimum Value offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents.

1G. Offer of coverage to employee who was not a full-time employee for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the calendar year.

1H. No offer of coverage (employee not offered any health coverage or employee offered coverage not providing Minimum Essential Coverage).

1I. Qualified Offer Transition Relief 2015: Employee (and spouse or dependents) received no offer of coverage, or received an offer of coverage that is not a Qualified Offer, or received a Qualified Offer for less than all 12 Months.

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1095-C Line 16: Safe Harbor Codes

2A. Employee not employed during the month.

2B. Employee not a full-time employee.

2C. Employee enrolled in coverage offered.

2D. Employee in a section 4980H(b) limited non assessment period.

2E. Multiemployer interim rule relief.

2F. Section 4980H affordability Form W-2 safe harbor.

2G. Section 4980H affordability federal poverty line safe harbor.

2H. Section 4980H affordability rate of pay safe harbor.

2I. Non-calendar year transition relief applies to this employee.

Source: IRS 2014 Instructions for Forms 1094-C and 1094-C dated 2/4/15

1095-C Part II: FT who elect coverage

Source: EBIA Dec 4 Employer Reporting

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1A

2C

1A

1A. Qualified Offer: MEC providing MV offered to full-time employee with

employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line ( i.e.: $92.38 per month 2014- $11,670 FPL) and Minimum Essential Coverage offered to spouse and dependent(s). Note: $93.18 for 2015 - $11,770

2C. Employee enrolled in coverage offered.

Line 15 blank since using 9.5 FPL

NOTE: Code 2C should be used for any month in which the employee enrolled, regardless if another code could also apply. 2C trumps!

1095-C Part II: FT who do not elect coverage

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1A

2G

1A. Qualified Offer: MEC providing MV offered to full-time employee with

employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and Minimum Essential Coverage offered to spouse and dependent(s).

2G. Section 4980H affordability federal poverty

line safe harbor.

Line 15 blank since using 9.5 FPL


1A

1095-C new VH employee, becomes FT

Hired Feb 15

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115 115 115

1H 1H 1H 1H 1H 1H 1H 1H 1H

2A 2C 2C 2C 2D 2D 2D 2D 2D 2D 2D 2D

1E 1E 1E

2A. Employee not employed during the month.

2D. Employee in a section 4980H(b) limited non assessment period. 2C. Employee enrolled in coverage offered.

1E. MEC providing MV offered to employee and at least Minimum Essential Coverage offered to dependent(s) and spouse.

$115 = Premium paid for lowest cost SELF only,

since rate of pay

Initial Measurement Period (6 mo) Admin Stability Period ->

1H. No offer of coverage (employee not offered any health coverage or employee offered coverage not providing Minimum Essential Coverage).



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Line 15 Enter employee share of the lowest cost monthly premium for self only offered when entering codes 1B, 1C, 1D or 1E If coverage is not offered or not provide MEC or MV, do not complete this line.


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Part III Complete lines 17-22 ONLY if

self funded coverage This is where covered individuals SSN will be entered. Complete one form for each employee who enrolls in the health coverage ( whether Full time or not – instructions note enrolled PT)

Reporting Basics: Self Insured ALE that offer coverage to non-employees (retirees, COBRA, directors) may use Form 1095 C part III or use Forms 1094-B/1095B

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Section 6055 Required Returns

Form 1094-B: Transmittal

2014 final instructions available

Fully Insured – Carriers Submit

Self Insured – Use series/combined

Form 1095-B: Offer & Coverage

Special Notes – In the Weeds

Each ALE member has its own independent obligation to file returns and furnish statements. Third parties can assist but cannot transfer ALE liability….

One Form 1095 C per ALE member for each FTE

READ INSTRUCTIONS (see page 10) if employee is an employee of more than one employer in an aggregated ALE during one calendar month and year.

Also See Q & A on Reporting of Offers of Health Insurance coverage by Employers (6056)

Q 22 – Designated Governmental Entity

Q 24 – Multiemployer Plan administration – considerations on who files?

NOTE: Employer is treated as offering health coverage to an employee if the employer is required

by a collective bargaining agreement (CBA) 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.

However, even if an employer goes this route, the fund will still need certain data elements from the

employer, such as the employee’s compensation or the safe harbor that the employer is using to

determine affordability under the ACA. So either way, communication is necessary. Additionally,

there is no similar rule for staffing companies.

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Penalties

48

• Penalties for violations of reporting requirements

– $100 per violation, up to $1.5M per year

– May be increased or decreased, depending on

circumstances

• Short-term relief from penalties

– Available for reporting related to 2015

coverage

– IF reporting entity shows good faith effort to

comply

– Applies to incorrect/incomplete information

reported or other failures due to reasonable

cause Source : Zywave Jan 20, 2015

Keeping It Straight – Form Filings ALE

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Type of

Employer

Type of

Reporting

Who

Reports and

Provides

Statement

Forms Filed

with the IRS

Employee

Statement

ALE with no

plan

6055 No reporting

required

None None

6056 Employer 1094-C,

1095-C (no

part III)

1095-C (no

Part III)

ALE with

insured plan

6055 Insurer 1094-B,

1095-B

1095-B

6056 Employer 1094-C,

1095-C (no

Part III)

1095-C (no

Part III)

ALE with self-

insured plan

6055 Employer

Combined

Reporting

1094-C,

1095-C

1095-C

6056

Keeping It Straight – Form Filings – Small Employer

50

Type of

Employer

Type of

Reporting

Who

Reports and

Provides

Statement

Forms Filed

with the IRS

Employee

Statement

Small

employer

with no plan

6055 No reporting

required

None None

6056

Small

employer

with insured

plan

6055 Insurer 1094-B,

1095-B

1095-B

6056 No reporting

required

None None

Small

employer

with self-

insured plan

6055 Employer 1094-B,

1095-B

1095-B

6056 No reporting

required

None None

What Can You Do Now?

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• Identify who will be responsible for reporting and who will be involved in that reporting (HR, IT, Finance, Tax, etc.).

• Review ACA IRS forms and instructions for an understanding of what information must be reported and where applicable data resides.

• Identify which vendor(s) will assist with compliance.

• Start collecting SSN/TIN for employee and, if applicable, for dependents.

• Determine approach & tools for tracking ACA eligibility and annual IRS reporting. Set affordability computation.

• Consider if an alternate “simplified “ reporting method makes sense for your organization – read instructions carefully to assess if fits.

• Save hours served data, offer of coverage notifications, waive of coverage documents, etc. Anticipate how you will respond to marketplace notices and/or an audit.

R. Edward Johnson, ASA, MAAA, ACA BB&T HCR Advisory Group

Any estimates presented here have been calculated prior to all regulations being issued for the Patient Protection and Affordable Care Act (PPACA). Future regulations may include clarifications, technical corrections, or guidance on complex calculations that may be required. As such, these estimates are not actuarial opinions. Financial and design decisions should only be made after careful consideration and not only on the estimates presented here. Additionally, financial and design decisions are the sole responsibility of the company or client attending this presentation.

Insurance products are offered by BB&T Insurance Services, Inc., BB&T Insurance Services of California, Inc., F.B.P. Insurance Services, LLC DBA Precept Insurance Solutions, LLC and DBA as Proview Advanced Administrators, LLC, and McGriff, Seibels & Williams, Inc., all subsidiaries of BB&T Insurance Holdings, Inc. BB&T Insurance Services, Inc., CA Lic #0C64544; BB&T Insurance Services of California, Inc., CA Lic #0619252; F.B.P. Insurance Services, LLC, CA Lic #0747466; McGriff, Seibels & Williams, Inc., CA Lic #0E83682.

BB&T and its representatives do not offer tax advice. The information provided should not be considered tax or legal advice. Please consult with your individual tax advisor and/or attorney regarding your individual circumstances.

©2015, Branch Banking and Trust Company. All rights reserved. Insurance.BBT.com

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