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HEALTH REFORM ADVISORY PRACTICE

Presented by

Edward Fensholt, J.D.

Scott Behrens, J.D.Compliance Services, Lockton Benefit Group

© Lockton Benefit Group 2016

ACA Reporting Update: What’s Done and Left to be Done, and Where the Bones are (Probably)

Buried

To View Webcast, Click Here

L O C K T O N C O M P A N I E S , L L C

Agenda

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ACA Reporting Issues

Other ACA Issues of Note

Wellness Program Update

What’s Next?

Questions

Agenda

L O C K T O N C O M P A N I E S , L L C

ACA Reporting Issues

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IRS allows a short-term reprieve from ACA reporting deadlines!

Employees may file their tax returns without the 1095-B or -C forms for 2015

What if it turns out the 1095-B or –C is wrong? Employees don’t need to amend their returns if the employees relied on other information supplied by the employer or insurer, about months of coverage in 2015

What other information would the employee rely on?

Memory

Enrollment materials

Payroll deductions

SBC? Exchange notice?

Hip-Hip Reporting Delay!

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Hip-Hip Reporting Delay!

ACA Employer Reporting Requirement

Original Deadline New Deadline

Forms 1095-C to Employees, etc.

Forms 1095-C to full-time employees and to any other employees or primary insureds (retirees, partners, COBRA beneficiaries) with coverage under the employer’s self-insured plan

Feb. 1, 2016(30-day extension available at the

IRS’s discretion)

March 31, 2016(no extension available)

Forms 1094-C and 1095-C to IRS

Paper filing of Forms 1094-C and 1095-C

Feb. 29, 2016(automatic 30-day extension available

via Form 8809)

May 31, 2016(no extension available)

Electronic filing of Forms 1094-C and 1095-C

March 31, 2016(automatic 30-day extension available

via Form 8809)

June 30, 2016(no extension available)

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1. Employers with 50 or more FTEs/FTEqs in 2014 report on their FTEs, in Part II of 1095-C

Why? Prove compliance with employer mandate (or claim an exemption from compliance)

How to count: Aggregate all members of the corporate family tree (controlled/affiliated services group); include bargaining unit employees even if getting coverage through the union

If at least 50 FTEs/FTEqs in the corporate family tree, allmembers of the corporate family tree with separate EINs must report separately, even if – considered alone – the members would be too small to be subject to any of this

If 50-99 FTEs/FTEqs in corporate family tree, no obligation to offer coverage for 2015, but must still report

New law: Allows employer to exclude employees (and their hours of service) receiving TRICARE/VA benefits (applies retroactively to 2014 for 2015 play-or-pay determinations/calculations)

Who does this benefit?

Who Must Report, and Why Are They Doing It?

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2. Each self-funded employer must report on all individuals covered for at least one day in 2015

Why? Help the individual prove compliance with the individual mandate

What if the plan is insured? The insurer will fulfill this obligation, on a Form 1095-B

Employer size doesn’t matter here…whether employer is subject to the employer mandate doesn’t matter…all that matters is that the employer offered self-insured coverage, and somebody took it

What about self-funded HRAs?

More on this later

What about retiree plans for pre-Medicare-eligible retirees?

What about group Medicare supplemental plans?

Who is covered?

Does it matter which parts of Medicare the retiree is enrolled in?

Who Must Report, and Why Are They Doing It?

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1. Full-time employees (FTEs) for any month of 2015

Why? Employee is basically receiving a copy of the information supplied by the employer to the IRS, to prove compliance with the employer mandate

FTE status is based on either the monthly measurement method or look-back measurement method (an ―ACA FTE‖)

Plan eligibility might not mirror ACA FTE status (e.g., some plans exclude PRNs, temps, interns etc. even though they might be ACA FTEs)…

…So, health plan eligibility is not the benchmark here…ACA FTE status is the benchmark

Mid-year changes in employment status are tricky (see accompanying grid)

Who Gets a Report (i.e., a 1095-C), and Why?

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2. Individuals covered under a self-funded plan for even a single day in 2015…

Why? So they can use the information on the form to prove compliance with the individual mandate

Not just ACA FTEs, but includes part-time employees, retirees, COBRA beneficiaries, partners, directors, contractors, and any others…

…but not individuals covered under a self-insured HRA if the employer sponsors the related medical plan

Doesn’t matter whether the related medical plan is insured or self-funded…the self-insured HRA coverage is not reported

It’s exempted because the reporting of the HRA coverage is redundant, for proving compliance with the individual mandate, with the reporting of the major med coverage

More on HRAs in a few minutes….

Who Gets a Report (i.e., a 1095-C), and Why?

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Don’t send a 1095-C to someone who was never an ACA FTE for even a single month, unless he/she was covered under self-funded plan of the employer for at least a day (but remember: Don’t report the self-insured HRA coverage if the employer sponsors the related insured or self-funded medical plan)

Employees in a “limited non-assessment period” as of Dec. 31 are not FTEs, even if working full-time hours…

New employee in a waiting period

New employee in initial measurement period

First partial month of employment

Self-employed individuals (e.g., partners, contractors, outside directors) are not FTEs

Don’t report on a non-FTE who was offered and declined coverage

Who Doesn’t Get A Report?

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By the Way…How Do We Determine FTE Status for Employees on Leaves of Absence?

FTE status is determined by looking back over the previous month (month-to-month method) or over the previous look-back measurement period (look-back measurement method)

No need to credit hours for workers’ compensationleaves of absence

No need to credit hours for payments under mandated programs under unemployment comp or disability leave laws

No need to credit hours for short- or long-term disability leave unless payments are contributed to by the employer

After-tax payment of premium by employee is not an ―employer contribution‖ for this purpose

What about the employer paying premium, and imputing the cost as taxable income to the employee?

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Which Code Goes Where? (aka ―Form 1095-C, Part II is Hard!‖)

Employee-by-employee, month-by-month determination of whether coverage was offered to an ACA FTE, if not why not, whether it was minimum value (MV) and affordable, and whether the employee was enrolled or not

If you need to report on one month, you need to report on all months Examples:

The non-calendar year delay applies for part of the year

Employee was hired or terminated mid-year (see COBRA discussion, later)

Employee in a FTE stability period for only part of the year

Calendar year reporting, even if plan runs on a non-CY plan year/policy year

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ACA Reporting Wrinkles

COBRA Coverage: An Inconsistent Approach

Final instructions and earlier IRS website posting are inconsistent!

Final instructions themselves treat the approach inconsistently, based on the nature of the qualifying event…

In any event…your COBRA vendor is not responsible for reporting this

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ACA Reporting Wrinkles

Reporting COBRA in Part II, Form 1095-C…

Terminations of FTE Employment

Treat the offer of COBRA as no offer (1H)

Treat enrollment under COBRA as no enrollment (don’t use Code 2C)…instead, show ―Not our employee‖….Code 2A

Reductions in FTE Hours (no termination)

The employee remains active, so use the appropriate coverage offer code on line 14, the cost on line 15, and whether covered or not (or other excuse code, such as 2B (Part-time)) on line 16

Ask first: Am I really stripping eligibility upon the reduction in hours, in the middle of a stability period/plan year, or should I wait to do that?

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Reporting COBRA in Part III, Form 1095-C…

Relevant if COBRA is provided under a self-insured plan

Self-insured COBRA coverage is reported in Part III regardless of how the offer is reflected in Part II…thus,

Part II might show Code 1H - No coverage offer - but Part III might show that coverage was supplied

Parts II and III serve different purposes

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

For Parts II and III (where COBRA is self-insured), distinguish the year in which the termination occurs from the year the individual begins while on COBRA For the year in which the termination occurs,

you’re reporting coverage offers and enrollment etc., up through the first full month after termination, then showing 1H and 2A for remainder of the year…but completing Part III accurately, if enrolled

If the individual began the year on self-insured COBRA, insert Code 1G on line 14, leave lines 15 and 16 blank, and complete Part III

Reminder: If COBRA coverage is insured (employer isn’t

reporting coverage in Part III of the 1095-C) and the covered individual is not an FTE for any month of the year (employer isn’t reporting coverage offers in Part II of the Form 1095-C)…there’s nothing for employer to report

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Retroactive Elections Under COBRA…

There can be considerable lag between a COBRA qualifying event and the beneficiary’s election of coverage (and a longer lag before the first month’s payment is due)

Example: Employee terminates Oct. 28, 2015, loses coverage under a self-insured plan. COBRA packet issued early December, former employee elects COBRA in January, makes first premium payment by late February.

COBRA coverage is retroactive

The Form 1095-C should reflect, in Part III, coverage for Oct., Nov. and Dec. 2015

If it doesn’t, need to issue corrected 1095-C

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Retiree Coverage: Like COBRA…

Again, distinguish between the year in which the retirement occurs from the year in which the individual is a retiree the entire year…

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Mergers and Acquisitions: Who’s on First?

Stock purchases

Asset purchases under a ―successor employer‖ theory, like with W-2s?

Example:

ABC Company acquires XYZ Company (stock purchase) in July 2015; both are subject to employer mandate at time of close

Who reports on XYZ?

What if ABC merges XYZ into ABC?

What if XYZ had been too small for the employer mandate or ACA reporting to apply, at the time of the close?

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Reporting Coverage Under an HRA

Generally, avoidable as long as employee is enrolled in another medical plan of the employer, whether insured or self-funded

Both coverages are MEC, but for individual mandate purposes, the IRS only needs to know about one…

Wrinkle: What if the individual is enrolled in the employer’s self-insured HRA, but has coverage under a plan sponsored by a spouse, domestic partner or parent?

Wrinkle: What if employee is enrolled in e’ee-only coverage, and the HRA reimburses dependents’ expenses (dependents may be enrolled elsewhere, or not enrolled at all)?

Wrinkle: What if the HRA is non-integrated?

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Reporting Coverage for Bargaining Unit Employees Employer gets a free pass on offering

coverage to full-time bargaining unit employees IF the employer makes contributions on their behalf to a multiemployer plan, and the plan offers MV and affordable coverage to the FTEs, and coverage for their spouses and children

Report as ―no coverage offer‖ (1H) on line 14, skip line 15, and code 2E on line 16, Form 1095-C, Part II

Doesn’t seem to matter whether the employee is actually enrolled in the union plan, or even eligible! (At least not for 2015)

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Does the Insurer Know All the Members of the Corporate Family Tree?

Some employers insure all members of the controlled group under a single contract, although there are multiple EINs; each EIN reports to the IRS separately

Some employers sponsor a fully-insured MEWA, covering affiliated but not sufficiently controlled employers; each EIN reports to the IRS separately

Will the ―Employer‖ on the insurer’s Form 1095-B match the ―Employer‖ on the employee’s Form 1095-C

No ―common paymaster‖ rule like there is for W-2s

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ACA Reporting Wrinkles (Issues Involving Multiple Lines)

Working with an ACA Reporting Vendor: Meeting of the Minds

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Generally asks what coverage was offered to the FTE, through the use of 9 different codes (1A – 1I)

Common issues

Coverage must be offered for the entire month to count as an offer for the month (although a failure here is often excused on line 16, with 1 of 9 other codes….)

Distinguish Part III of Form 1095-C and Form 1095-B, for individual mandate purposes

Should I use Code 1A where I can, or not? What if I do?

Code 1A: MV offer to employee, coverage offered to family, employee-only tier is less than 9.56% of the poverty level for the lower 48 states

Why we were not thrilled with Code 1A when first announced

Why we are coming around on the issue…

Line 14 Issues – Coverage Offers

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Amount of the employee’s share of the lowest-cost monthly premium for self-only coverage providing MV

Common issues

Only complete if coverage offer was MV, but don’t complete if 1A or 1I is used

Use the value of the coverage offered, not necessarily the coverage selected

Don’t use the wellness rate even if the employee earned the wellness rate, unless the premium differential relates solely to non-tobacco use…then assume everyone earns the non-tobacco incentive

For 2015, opt-outs/cashable flex credits do not negatively affect affordability

Line 15 Issues – Cost of Coverage

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Line 16 Issues - Penalty Excuses, Affordability Safe Harbors, etc.

Generally explains why the employer shouldn’t be subject to a penalty for failing to offer MV/affordable coverage through the use of 9 different codes (2A – 2I)

Common issues 2C (employee enrolled) trumps other codes in almost

all circumstances (2E applies if collectively bargained transition relief applies, 2A applies for COBRA coverage following termination of employment)

On that note, don’t use 2I (non-calendar year transition relief) unless it is necessary

Affordability safe harbor codes apply only if MV coverage is waived

Line 16 can be left blank (e.g., if an FTE rejects coverage and no safe harbor applies)

Only one affordability safe harbor can apply to any group of similarly situated employees

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IRS Mends the Affordability Safe Harbor ―Disconnect‖

Employer mandate requires offer of ―affordable‖ coverage

Statute: Employee-only coverage shouldn’t cost more than 9.5% of household income

9.56% for 2015, 9.66% for 2016

Employers don’t know what ―household income‖ is for an employee

IRS offers three safe harbors: Don’t ask employee to pay more than 9.5% of:

W-2 pay

Rate of pay x 130 hours

Poverty level for state where employee resides

Disconnect is mended retroactively; safe harbors now inflation-adjusted as well

So, when reporting on Line 16 of 1095-C, use 9.56%to determine whether a safe harbor code applies (9.66% next year)

…Speaking of Affordability…

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…Speaking of Affordability…

HRAs and flex credits might affect affordability calculations in a good way

Might be applied to reduce the amount the employee is asked to pay, for purposes of an affordability calculation

HRAs: If the benefit may be applied only to pay premium, OR to pay premium and reimburse cost sharing

Flex credits: If the credits:

Cannot be taken as cash

Can only be used to buy minimum essential coverage and to reimburse medical care expenses

Generally, this rule will apply after 2016, except for new flex credit programs (will apply to them for 2016)

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…Speaking of Affordability…

EXCEPTION: Service Contract Act and Davis-Bacon Act

At least through 2016, may continue to offer employees choice of fringe contribution as a benefit or as cash, without creating an affordability problem

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…Speaking of Affordability…

A cash opt-out amount will soon be added to the employee's contribution to determine if coverage is affordable

Example: Ed is offered employee-only coverage at a monthly cost of $100. However, if Ed waives coverage, he receives $200 cash. Because the receipt of the cash opt-out credit depends on Ed waiving medical coverage, the IRS concludes that Ed’s ―cost‖ for the medical coverage includes the cash he had to forego in order to enroll in the medical plan.

Thus, in our example, Ed’s monthly cost for employee-only coverage is deemed to be $300 (the $100 per month contribution plus the $200 opt-out ).

Rule applies for plan years beginning on or after January 1, 2017.

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1094-C: Transmittal to the IRS

The primary purpose of the Form 1094-C is for employer to prove compliance with the requirement to offer minimum essential coverage to FTEs and their children (the ―Tier 1‖ or ―aggregate‖ obligation)

Common issues

One 1094-C must be ―authoritative‖ even if various divisions of the same employer submit separate data, or employers sends its 1095-Cs to IRS in batches

Controlled group member? Y/N on line 21, identify months in Part III, identify other members in Part IV

Line 22 is confusing, especially box (c)

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1094-C: Transmittal to the IRS

Line 22

(a) Did the employer make a ―qualifying offer‖ to one or more FTEs?

(b) If one or more employees didn’t get a qualifying offer for one or moremonths, did at least 95% of FTEs receive one?

(c) 4980H Transition Relief:

There’s a lot of transition relief under the employer mandate

This question is asking about two possibilities: 50-99 FTEs/FTEqs in 2014, OR are you ―paying instead of playing‖ and claiming the ―Free 80‖ in your penalty calc?

(d) Did you make an offer of MV and affordable coverage to at least 98% of theemployees for whom you’re preparing a 1095-C?

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1094-C: Transmittal to the IRS

Part III is where the employer attests to Tier 1/‖aggregate‖ compliance on month-by-month basis

Simple Y/N for Column (a)

95% = 70% for 2015

Ignore employees not offered coverage because in a limited non-assessment period

Pretend you offered coverage to bargaining unit members on whose behalf you contributed to a multiemployer plan offering MV/affordable coverage (the ―2E‖ crowd)

Pretend you offered coverage to dependent children even if you didn’t, but were making efforts to install that coverage for 2016

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1094-C: Transmittal to the IRS

FTE Counts for Column (b)

Ignore the same employees ignored in column (a) due to limited non-assessment periods

Free pass on this column if checked box (d) on line 22 – 98% offer method

Total Employee Counts for Column (c)

Count everyone, even part-timers, employees in a limited non-assessment period (i.e., waiting period, initial measurement period and related admin period), etc.

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Reports are due to the IRS by May 31, 2016 if using paper and June 30, 2016 if e-filed

Employers submitting 250 or more reports must e-file unless they obtain a waiver.

Waivers can be claimed on IRS Form 8508 and must be filed by May 16, 2016.

Waivers are not automatic

The e-filing system is cumbersome and requires technical expertise—both with respect to filing out the forms and coding/electronic data transmission/XML

For example . . .

Transmitting Forms to the IRS

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A Form 1094-B that Ends Up Looking Like This . . .

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Is Submitted Looking Like This

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E-Filing Steps

Register to use IRS e-Services

You’ll need at least two people from the employer to do this including at least one responsible official and two contacts (the responsible official can be one of the contacts). Responsible official is an high ranking employee who has authority over the filing process (e.g., president, treasurer, CEO, CFO).

Contact is a person with actually transmits the forms and can respond to IRS inquiries on a day-to-day basis.

Registration requires personal information like SSN, DOB, and adjusted gross income.

Apply for an Information Return Transmitter Control Code (TCC)

Employers can apply as an issuer, transmitter, or software developer

Employers apply for a TCC based on their role:

Issuer – employer is submitting its own returns only

Transmitter – employer is submitting its returns and returns for other employers (e.g., employer submitting for other EINs in the employer’s family tree)

Software Developer – entity designing software for others to use when submitting returns

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Test communications with AIR System

The IRS uses a set of sample fact patterns, which must be converted into XML format and test submitted to confirm that the data transmission will be accurate

Electronically file by June 30, 2016

The IRS AIR Program webpage has numerous resources available including tutorials with screenshots access to webinars and explanations of the various technical requirements

E-Filing Steps

L O C K T O N C O M P A N I E S , L L C

Other ACA Issues of Note

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Employer Mandate – Inflation Adjustments & Transition Relief

Applicable Large Employer (ALE) determinations

50–99 delay expiring

Exclude veterans with TRICARE or VA coverage when counting FTE/FTEqs—this applies to 2014 determinations too

Tier 1 changes

Inflation adjustment to $2,160

Minimum essential coverage must be offered to 95% of full-time employees

―Free 80‖ reduced to ―Free 30‖

Tier 2 changes

Inflation adjustment to $3,240

More to come on affordability determinations

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Cadillac Tax Delay

Delayed to 2020 (from 2018)

40 percent tax on health benefits with values exceeding $10,200 individuals; $27,500 for ―other than individual coverage‖

2020 estimates: $10,950/$29,450

Cadillac tax is deductible

Solves the problem of ―gross up‖ when employer remits tax to insurers and TPAs who then pay IRS

Be heard on this issue!

http://www.fightthe40.com/

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Health Insurer Tax Delay – Medical Device Tax Delay

Health Insurer Tax

Has been in place since 2014

Billions in taxes due from the industry, each insurer pays a portion based on market share, passes along cost in premium charges

2017 Tax Was to Be $13.8 Billion

Delayed one year

Should be no surcharge from carriers for 2017

Medical Device Tax

Has been in place since 2013

Adds 2.3% tax to medical devices except for some at retail outlets

Tax for 2016 and 2017 is delayed

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Auto Enrollment Repeal

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Other Potential Ugliness

Experience Gains Under MEC Programs

Watch your step!

Break in Service Rules

13 weeks for most

26 weeks for educational organizations

IRS: Regs will provide that employees providing services to an educational organization must have a ―meaningful opportunity to provide services‖ for the entire year, or the 26-week rule will apply

L O C K T O N C O M P A N I E S , L L C

Wellness Program Update(No Good Deed Goes Unpunished)

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Wellness Programs Backdrop

Comprehensive HIPAA/ACA Rules

Crafted by IRS, DOL and HHS

Wellness universe has two halves:

Participation-based programs (largely unregulated)

Outcomes-based programs (significant regulation, incentives limited to 30% of cost of coverage, 50% for tobacco-related programs)

EEOC Proposed Rules

ADA: Wellness universe has two halves:

Programs not involving a disability inquiry/medical exam

Programs that do (can’t deny enrollment for not participating, incentives limited to 30% of cost of employee-only coverage)

GINA: Wellness universe has two halves:

Programs not asking for genetic information (family medical history)

Programs that do (can’t ask employee for this at enrollment, or for incentive at any time)

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Wellness Programs and the EEOC

EEOC loses another wellness case Issue centers on health risk assessments and

penalties for not participating

ADA prohibits medical inquiries unless ―voluntary,‖ and voluntary means no ―penalty‖ What’s a penalty?

Does it matter? ADA includes a ―bona fide benefit plan‖ safe harbor or free pass

Proposed EEOC rules prohibit an employer from conditioning coverage on submission to a medical inquiry

EEOC v. Flambeau (W.D. Wis.) – bona fide plan exception allows employer to condition health plan enrollment on employee completing health risk assessment (similar result to Broward County case)

EEOC final regulations on wellness incentives due later this year…what then?

For now, move forward with caution

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Wellness Programs and the EEOC – Part Deux

Genetic Information Nondiscrimination Act Can’t collect genetic information at open

enrollment, or at ANY time in exchange for an incentive

―Genetic information‖ includes family medical history

Response: Wellness vendors stopped asking employees for family medical history

What About Incentives to an Employee, if the Spouse Completes a Health Risk Assessment? The spouse’s information about his/her health is

―family medical history‖ vis-à-vis the employee

EEOC proposed regs: Employers can provide the incentive, but it’s limited, and requires an advance authorization

Cannot ask spouse for his or her family medical history, nor for the children’s

L O C K T O N C O M P A N I E S , L L C

What’s Next?

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U.S. Supreme Court

ERISA preemption of VT all payer claims database (similar to Colorado program)?

Contraceptive mandate requirement to provide HHS or insurer/TPA opt-out form

See attached summary of current landscape)

Issues in a regulatory black hole

New 105(h) regulations

HPID

Things to Look Forward To

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Health Insurance Exchanges – Notice of Employee’s Eligibility for Premium Tax Credit

Sometime later this year, federal exchanges will likely start issuing notices to employers if an employee receives tax credit for exchange coverage

How does the employer demonstrate an offer of coverage?

Employers will have 90 days to dispute ruling

IRS, not the exchange, will assess the penalty

IRS very tight lipped on mechanics of appeals process

Something Not to Look Forward To

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Something Else To Not Look Forward To

HHS to initiate its second round of HIPAA audits

Round #1 was pilot audit program back in 2012

See http://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/index.html

HHS ―wall of shame‖ continues to grow

IRS: If breach, ID protection is tax-free to employees

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Status quo will be maintained if a Democrat wins the White House (or loses the White House but the Republicans lose the Senate)

Big shake ups if Republicans hold the Senate and win the White House? Maybe.

Republicans generally oppose employer and individual mandates, but there doesn’t seem to be a cohesive strategy for how to pay for repeal or what to do instead. Something is bound to happen, but what?

Rubio and Cruz would repeal the ACA and give Americans a tax credit to buy individual coverage (like auto insurance), and across state lines

Trump would repeal the ACA and ―replace it with something terrific‖

Clinton says she’d keep the ACA, but not the Cadillac tax, and she’d control Rx prices and limit cost sharing

Bernie Sanders: ―Spend trillions, go single-payer‖

Our Election 2016 Hot Take

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Questions?

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www.lockton.com

© 2014 Lockton, Inc. All rights reserved.Images © 2014 Thinkstock. All rights reserved.

Our Mission

To be the worldwide value and service leader in insurance brokerage, risk management, employee benefits, and retirement services

Our Goal

To be the best place to do business and to work

RISK MANAGEMENT | EMPLOYEE BENEFITS | RETIREMENT SERVICES

www.lockton.com

© 2015 Lockton, Inc. All rights reserved.