ACA Reporting Requirements Who, What, When? July 14, 2015.
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Transcript of ACA Reporting Requirements Who, What, When? July 14, 2015.
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ACA Reporting RequirementsWho, What, When?
July 14, 2015
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Presenters
Stew BeltzDirector, Health & Welfare Benefits
Todd IngvesDirector, Information Management
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Agenda
• Reporting requirements overview
• Who reports?
• What to report?
• When to report?
• Preparing to report
• If you do not report
• Resources
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Reporting Requirements Overview
• Report member’s healthcare coverage
• Required for compliance with key ACA components:
• Individual mandate
• Employer mandate
• Qualification for exchange subsidy
Reporting to the IRS and Individuals
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Reporting Requirements Overview
• Individual mandate: Must maintain minimum essential coverage for self and dependents
• Employer mandate: Large employers must offer
• Minimum essential coverage to 95% of full-time employees and dependents (70% in 2015) and
• Affordable coverage providing minimum value to full-time employees and dependents
Review of Mandates
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Reporting Requirements Overview
• Health plans report individual coverage for individual mandate purposes
• Use Forms 1094-B and 1095-B
• Large employers provide information for government to enforce employer mandate and verify individual’s eligibility for premium tax credits
• Use Forms 1094-C and 1095-C
Section 6055 Requires Section 6056 Requires
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Who Reports
• Health insurance carriers (and HMOs)
• Group health plan sponsors (e.g., church plans -- the Board)
• You, if you are an Applicable Large Employer (ALE)
Health Plans Large Employers
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Who Reports
• Essentially same criteria as used to determine the 50-FTE threshold for ACA employer mandate
• ALE = employs on average 50 or > full-time employees
• Full-time employee = employee employed on average 30 or > hrs/wk
• Full-time equivalent employee = combination of employees, each of whom individually is not a full-time employee, but who, in combination, are equivalent to a full-time employee
Applicable Large Employer Criteria
See pensions.org/healthcarereform for ACA-related resources!
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What Is an Aggregated ALE Group?
• Employer Identification Number (EIN) or Federal Tax Identification Number (TIN) is shared by more than one organization; or
• 80% or more of an employer’s operating funds are provided by a different organization and there is common management between the organizations; or
• 80% or more of the members of the governing body of an organization are either representatives of, directly or indirectly control, or are controlled by another organization.
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What To Report
• Reporting involves filing information with the IRS and disclosure to individuals
• IRS filing:
• Includes individual information and transmittal form
• May be done electronically or by paper (if more than 250 forms, must submit electronically)
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What To Report
• Form 1094-B: Transmittal of Health Coverage Information Returns
• Form 1095-B: Health Coverage
• Employee statement
Board of Pensions
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What To Report
The Board will provide standard IRS identifying information.
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What To ReportThe Board will provide standard IRS identifying information for all parties.
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What To Report
• Form 1094-C: Transmittal form or cover sheet that contains summary information to accompany Form 1095-C
• Form 1095-C: Detailed form naming each employee being reported
• Employee statement
Large Employer
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What To Report1094-C Transmittal Form: Summary from each employer, Part I
Each Applicable Large Employer provides information identifying each reporting entity, as applicable.
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What To Report1094-C Transmittal Form: Summary from each employer, Part II
ALE completes this part to tell IRS if:
1) This is the final set of data
2) Report is specific to 1 employer or set of employers
3) An eligible reporting method is being used
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What To Report1094-C Transmittal Form: Summary from each employer, Parts III & IV
Part III provides a month-by-month summary of minimum essential coverage offered to full-time employees and dependents
Part IV identifies to the IRS any other affiliated
employers under the IRS “Controlled Group” rules
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What To Report1095-C Form: Provides detail on each full-time employee, Parts I & II
Part I: Basic employee tax information, similar to Form 1099
Part II: Confirms whether the employee was offered affordable coverage that meets minimum value requirements
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What To Report1095-C Form: Provides detail on each full-time employee, Parts III
Skip Part III of Form 1095-C!
The Board reports member and dependent details in its forms.
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What To ReportEmployee Statement
Each employee must receive a copy of the Form 1095-C that you submit to the IRS on their behalf
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When To Report
Deadline Type Deadline Date*
Statement to employees
Paper IRS report
Electronic IRS report
Annual reporting requirements start in early 2016 for coverage provided in 2015
*Same as for W-2s
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Preparing To Report
• Determine size of employer on an Aggregated ALE Group basis
• Decide who has data and who will prepare the report
• Is data available month-by-month?
• Is data available employer-by-employer?
• Is third-party reporting an option?
Large Employer Should Begin Now
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If You Do Not Report
• Failure to file and/or furnish statement are each subject to a penalty of:
• $100 per form/statement
• Up to $1.5 million
• Subject to reductions for corrections and other adjustments
• For 2015, no penalty will apply if good faith effort to comply can be demonstrated
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Board Resources
• ACA requirements summary, by year
• Preparing for the Employer Mandate
• Worksheet To Determine Total Employee Count
• Additional resources and links
pensions.org/healthcarereform
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IRS Resources
• irs.gov/aca
• irs.gov
• Internal Revenue Code Sections 6055, 6056 & 4980H
• Forms 1094-B, 1095-B, 1094-C & 1094-C (including instructions and questions and answers)
• Information Reporting by Applicable Large Employers
• Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters (Publication 5165)
• Understanding employer reporting requirements of the health care law
• IRS Controlled and Affiliate Service Groups
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Questions?