Affordable Care Act (ACA) Reporting Requirements€¦ · Purpose of Reporting Employer • Covered...

Affordable Care Act (ACA)Reporting Requirements

Holly Murphy

Senior Attorney, TASB Legal Services

July 16, 2015

Overview

How reporting applies to your district

Form 1095-C

Form 1094-C

www.irs.gov/pub/irs-pdf/f1095c.pdf (1095-C)

www.irs.gov/pub/irs-pdf/f1094c.pdf (1094-C)

www.irs.gov/pub/irs-pdf/i109495c.pdf (combined instructions)

Purpose of Reporting

Employer

• Covered employer: full-time employees– Offer of coverage

– Affordability

• Self-insured employer: plan enrollment (self-insured)

Employee

• Eligibility for premium tax credits

• Coverage for self and dependents

of instructions:

Purpose of Form

Even if you fully comply with ACA, you 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 full-

employees*

Form 1095-C for each full-

time employee

- Form 1095-C for each full-

time employee

-Form 1095-C for each

employee who was not full-

time but who enrolled in

coverage

Which Districts Must Report

Pages 1-2 of instructions: Who Must File

* Including workforce extender (full-time equivalents as defined by ACA)

TRS-ActiveCare

PPOs: “self-funded multiple employer plans”

HMOs: fully-funded plans

< 50 full-time

employees*

not apply

>/= 50 full-

employees*

time employee

coverage

Pages 1-2 of instructions: Who Must File

< 50 full-time

employees*

not apply

>/= 50 full-

employees*

time employee

coverage

ActiveCare: • PPOs only• Includes COBRA participants

www.irs.gov/pub/irs-pdf/f1095b.pdf (form)

www.irs.gov/pub/irs-pdf/f1094b.pdf (transmittal)

www.irs.gov/pub/irs-pdf/i109495b.pdf (instructions)

Calendar Year

Reporting Period

Even if your district has a non-calendar year plan

Reporting Deadlines

January 31: statements to employees(February 1 for 2016)

of instructions: Furnishing Forms 1095-C to Employees

Reporting Deadlines

February 28: reports to IRS if filing on paper(February 29 for 2016)

of instructions: When to File

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. 13239 (Mar. 10, 2014)

1095-C: Employee Information

Voluntary for 2014!

of instructions: Reminders

Part I

Part II

Part III

Three Parts

1095-C: Which Employees

• Large employer: every full-time employee

• Self-insured employer: every enrollee, regardless of whether full-time

Full-time Employees

Employees who enroll

Full-Time Employee

Full-time even one calendar month that calendar year

• Every full-time, regular employee

• Every substitute, temporary, or part-time employee who works 130 or more hours in even one month

of instructions: Who Must File (first paragraph)

Employee and district information

Part I

of instructions: Part I

Offer of coverage and cost

Part II

Pages 6-7 of instructions: Part II –Employee O0ffer of Coverage

Whether employee and/or family was eligible for coverage – Series 1 codes

Line 14

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.

of instructions

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 self-

insured coverage• 1H: No offer• 1I: Qualifying Offer Transition Relief

of instructions

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 self-

insured coverage• 1H: No offer• 1I: Qualifying Offer Transition Relief

Series 1 Codes for Texas ISDs

• 1E: Offer to employee, spouse, and dependents

• 1G: Employee not full-time and enrolled in self-insured coverage

• 1H: No offer

Series 1 Codes

• 1E: Offer to employee, spouse, and dependents

• 1G: Employee not full-time and enrolled in self-insured coverage

• 1H: No offer

• Employee was not full-time AND•Employee enrolled in self-insured coverage• All 12 months

Net cost to employee for lowest-cost, employee-only coverage.

Line 15

Only if code 1B, 1C, 1D, or 1E was checked on Line 14

Line 15

of instructions

Safe Harbors and other relief–series 2 codes

Line 16

Pages 7-8 of instructions

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

of instructions

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

Only for self-insured plans

ActiveCare: PPOs

Part III: Enrollment Reporting

Pages 8-9 of instructions

Part III

For each covered individual

Employer TRS

Designating TRS for Enrollment Reporting

District leaves 1095-C, Part III blank

TRS will report on 1095-B

< 50 full-time

employees

Employer reporting

does not apply

Form 1095-B on all persons who

enrolled in coverage

>/= 50 full-

employees

- Form 1095-C for

each full-time

employee

- Parts I and II

- Form 1095-C for each full-time

employee

- Parts I and II

- Part III if employee enrolled in

self-insured coverage

-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)

Fully-Insured v. Self-Insured

Likely conditions for TRS to be DGE

• Deadline to designate TRS

• District retains responsibilities:

– Tax id numbers on enrollees

–Current addresses

– Full-time employee reporting

–Cost of delivering statements to employees

District retains liability for shared responsibility penalties

1094-C: Employer Information

Voluntary for 2014!

of instructions: Reminders

Four Parts

Part I

Part II

Four Parts

Part III

Four Parts

Part III

Part I

Part IV

Coversheet for 1095-C

• One Form 1094-C with each batch of 1095-Cs filed with the IRS

1095-C 1095-C1095-C

Part I

District information

“ALE Member Information”

ALE = Large employer

One or more entities that are treated as a single employer under the ACA.

26 C.F.R. § 54.4980H–1(a)(5)

Part II

Authoritative Transmittal

• One 1095-C is designated an Authoritative Transmittal

• The Authoritative Transmittal includes aggregate, employer-level

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

of instructions: Part II – ALE Member Information, Line 19

Line 22: Certifications of Eligibility

Check each applicable box

Certifications of Eligibility

• Qualifying Offer Method

• Qualifying Offer Method Transition Relief

• Section 4980H Transition Relief

• 98% Offer Method

Only on Authoritative Transmittal

Part III

Column a: Substantial Compliance

Pages 5 and 12 of instructions

Column b: Full-Time Employee Count

of instructions

Column c: Total Employee Count

of instructions

Column d: Aggregate Group Indicator

of instructions

Column e: Section 4980H Relief

of instructions

Code A or Code B

Section 4980H Transition Relief

• 50-99 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

of instructions: Section 4980H Transition Relief; page 13

Code B

Code A

Evaluate Data Systems

Which elements do you already track?

What needs to change?

Which ones do you need to track?

Can you automate tracking and reporting?

Questions?

Affordable Care ActReporting Requirements

Thank you!

Affordable Care Act (ACA) Reporting Requirements€¦ · Purpose of Reporting Employer • Covered...

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