ACA Reporting and Recordkeeping: Are you Prepared?

Transcription

1 Bottom Line Driven Health Benefits Planning ACA Reporting and Recordkeeping: Are you Prepared? Jeffery A. Schultz Phone: ext Vice President, BeneCo of Wisconsin This webinar is provided for informational purposes only, not intended to be tax advice, and is not intended or written to be used, and cannot be used by the recipient to avoid any federal tax penalty that may be imposed, or to promote, market or recommend any referenced entity, investment plan or arrangement. Additionally, it is not intended to be applicable to a particular fact situation and it cannot be used to form the basis of an attorney-client relationship. Please seek competent advice to determine the applicability of this information, if any, to your particular situation. Innovation. Dedication. Knowledge. Purpose. Integrity. Vision. Talent. Results.

2 Who We Are BeneCo of Wisconsin, Inc.: A member of The Benefit Companies, a privately held company. Have been providing insurance and employee benefits consulting since A full service benefits firm serving over 1,200 companies and organizations ranging from 10 to 50,000 employees. Headquartered in Brookfield, WI with additional Wisconsin offices in Green Bay, and Plymouth. -2- ACA 2015: Ready, Set, Comply

3 What Employers Need to Do in 2015 Ask these questions: 1. Do we understand and know how to apply the 2015 Transition Rules? 2. Have we determined if our Wellness Plan is both ACA and EEOC Compliant? 3. What is our defined strategy to avoid the 2018 Cadillac Tax? 4. Will our plan offerings be strategically affordable or unaffordable? 5. Are our systems capable of collecting the proper information for the 2016, 6055 and 6056 reporting? 6. Are we moving employees towards an ownership health care paradigm? -3- ACA 2015: Ready, Set, Comply

4 Jeff Schultz Vice President BeneCo of Wisconsin Greg Storm, J.D Shareholder, Benefits Attorney Reinhart Boerner Van Deuren s.c. -4- ACA 2015: Ready, Set, Comply

5 Topics for Discussion Updated IRS Reporting Timeline Overview of Employer Reporting Requirement Information You Must Collect & Disclose Who Must Receive When Requirements Take Effect Purpose of Reporting IRS Forms Transitional Relief Reporting Challenges & Complexities Planning for Reporting Requirement What do I do now? -5- ACA 2015: Ready, Set, Comply

6 IRS Reporting Update -6- ACA 2015: Ready, Set, Comply

7 IRS ACA Reporting Timeline February 4 th, IRS releases Final Reporting Forms for 2014 tax year 2015 Forms are not expected to change February 1 st, Employee statements are due to employees February 29 th, 2016 Information due to IRS (if paper filing) March 31 st, 2016 Information due to IRS (if filing electronically) Electronic filing is required for employers with 250 or more employees -7- ACA 2015: Ready, Set, Comply

8 Update: IRS ACA Reporting Final Forms B Transmittal of Health Coverage Information Return B Health Coverage C Transmittal of Employer-Provided Health Insurance Offer and coverage Information Return C Employer-Provided Health Insurance Offer and Coverage -8- ACA 2015: Ready, Set, Comply

9 Where Can I Find the Forms? Government website links: ACA 2015: Ready, Set, Comply

10 Purpose of Reporting Requirement Information provided will be used as part of the determination of whether or not an employee is eligible for a subsidy Purpose of the forms is to administer the Individual Mandate and the Employer Shared Responsibility ("Employer Mandate") penalties -10- ACA 2015: Ready, Set, Comply

11 IRS Reporting Forms Administration Compiling the information creates a significant administrative burden for the employer Reporting is compiled on a month by month basis -11- ACA 2015: Ready, Set, Comply

12 Information You Must Collect & Disclose -12- ACA 2015: Ready, Set, Comply

13 Employer Must Collect & Disclose Social Security Numbers of employees, spouses and dependents Names and employer ID numbers of other employers within their controlled group of employers Number of full-time employees for each calendar month Number of all employees for each calendar month -13- ACA 2015: Ready, Set, Comply

14 Employer Must Collect & Disclose Months of coverage for each covered individual Employee s share of the lowest-cost monthly premium for self-only, minimum value coverage for each calendar month The applicable Safe Harbor for each calendar month -14- ACA 2015: Ready, Set, Comply

15 Employer Must Collect & Disclose Certifications of eligibility Months in which you offered minimum essential coverage, by employee, and what type of coverage offered (i.e., self, family, individual + dependents, etc.) Months in which you as an employer were a member of a controlled group -15- ACA 2015: Ready, Set, Comply

16 Goal of the C Forms (1094-C & 1095-C) Report to the IRS an employer s compliance with the Employer Mandate and provide individual taxpayers tax records Certify employee categories for their stability period: Full Time vs Part Time Certify plans offered meet 4980H requirements and indicate who was offered coverage: MEC, MV, Coverage availability, Affordability Help employees avoid paying individual mandate tax if not necessary -16- ACA 2015: Ready, Set, Comply

17 Certifying Stability Period Results Measurement Period Results for Each Employee: Full-Time or Part-Time 1095-C 1094-C Full-Time Offered & Enrolled Parts I, II, III Total Full-Time Count Offered & Waived Not Offered Parts I, II Parts I, II Total Employee Count Part-Time Offered & Enrolled Not Offered or Offered & Waived Parts I, II, III -17- ACA 2015: Ready, Set, Comply

18 Certifying Affordability Results Coverage Type Offered and Monthly Self-only Low Plan Cost 1095-C Full-Time Offered & Enrolled Offered & Waived Part II, Lines Not Offered >1 Month Part-Time Offered & Enrolled Part II, Lines 14 & 16 Unionized* Employee contribution? Part II, Lines * Only if plan administered by a multi-employer plan ACA 2015: Ready, Set, Comply

19 Who Must Receive the Information? -19- ACA 2015: Ready, Set, Comply

20 Who Must Receive Information is required to be reported to all full-time employees, including whether an offer of health coverage was or was not made Self Insured Plans must report for all enrolled regardless of their full-time status Applies to all large employers regardless of whether you offer health coverage to all, none, or some of your full-time employees -20- ACA 2015: Ready, Set, Comply

21 Where is the employee getting information from? Fully Insured Employers 1095-C statement from the Employer Parts I & II only 1095-B statement from the Insurance Carrier Self-Funded Employers C statement from the Employer Parts I, II & III -21- ACA 2015: Ready, Set, Comply

22 IRS Forms -22- ACA 2015: Ready, Set, Comply

23 1094-B -23- ACA 2015: Ready, Set, Comply

24 1095-B -24- ACA 2015: Ready, Set, Comply

25 1094-C -25- ACA 2015: Ready, Set, Comply

26 1094-C -26- ACA 2015: Ready, Set, Comply

27 1094-C -27- ACA 2015: Ready, Set, Comply

28 1095-C -28- ACA 2015: Ready, Set, Comply

29 Form 1095-C, Part II ACA 2015: Ready, Set, Comply

30 Code Series 1, Offer of Coverage Code 1A 1B 1C 1D 1E Description Qualifying Offer: MEC/MV with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and at least MEC offered to spouse and dependent(s). MEC/MV offered to employee only. MEC/MV offered to employee & MEC offered to dependents. MEC/MV offered to employee & MEC offered to spouse. MEC/MV offered to employee & MEC offered to dependents and spouse. 1F 1G 1H MEC NOT providing minimum value offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents. 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. No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage) 1I Qualifying Offer Transition Relief ACA 2015: Ready, Set, Comply

31 Form 1095-C, Part II ACA 2015: Ready, Set, Comply

32 Code Series 2 Section 4980H Safe Harbor Code Code 2A 2B 2C 2D 2E 2F 2G 2H 2I Description Employee not employed during the month Employee not a full-time employee Employee enrolled in coverage offered Employee in a section 4980H(b) Limited Non-Assessment Period Multiemployer interim rule relief Section 4980H affordability Form W-2 safe harbor Section 4980H affordability federal poverty line safe harbor. Section 4980H affordability rate of pay safe harbor Non-calendar year transition relief applies to this employee ACA 2015: Ready, Set, Comply

33 Transitional Relief -33- ACA 2015: Ready, Set, Comply

34 IRS Filing Requirement Transitional Relief All Applicable Large Employers must report in 2016 for each calendar month in 2015 Employers eligible for Transitional Relief still need to report -34- ACA 2015: Ready, Set, Comply

35 Reporting Challenges & Complexities -35- ACA 2015: Ready, Set, Comply

36 Reporting What Makes This So Complex? New ACA definitions of old terms New ACA terminology 18 Pages of Complex IRS Instructions Multiple IRS Forms to Complete Multiple Sections that change based upon specific circumstances Data coming from multiple systems Tracking of breaks in services, FMLA, military leave, jury duty Translation of your data into coverage codes by month Data integrity Timing of reporting along side W-2 Benefit/HR Teams running at 120% of capacity Every month you wait you must go back and get data An environment of changing ACA regulation -36- ACA 2015: Ready, Set, Comply

37 Planning for Reporting -37- ACA 2015: Ready, Set, Comply

38 Employer Planning Get all the ACA stake holders together to discuss: Benefits Payroll Human Resources CFO IRS Reporting is not a Benefits Problem it is a Compliance Problem -38- ACA 2015: Ready, Set, Comply

39 Employer Planning Who is responsible for accurate and timely reporting within your organization? Specifically identified on the IRS Form. How many different systems is the required information in? Do you have the ability to compile, output and distribute the forms with your current resources? Do you need to enlist a third-party resource to help you complete? -39- ACA 2015: Ready, Set, Comply

40 What Employers Need to Do in 2015 Ask these questions: 1. Do we understand and know how to apply the 2015 Transition Rules? 2. Have we determined if our Wellness Plan is both ACA and EEOC Compliant? 3. What is our defined strategy to avoid the 2018 Cadillac Tax? 4. Will our plan offerings be strategically affordable or unaffordable? 5. Are our systems capable of collecting the proper information for the 2016, 6055 and 6056 reporting? 6. Are we moving employees towards an ownership health care paradigm? -40- ACA 2015: Ready, Set, Comply

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42 We are grateful AM 620 WTMJ has asked BeneCo to host a radio series to educate listeners on how best to tackle the ins and outs of the Affordable Care Act (ACA). Focused primarily on educating: Business Owners, CEO's, CFO's and HR professionals; we will help them determine if ACA is a "Top 3" or "Top 30" business priority. Tune in to hear us discuss critical ACA challenges to business. Next show scheduled for July 11 6:00pm. For that podcast or others: ACA 2015: Ready, Set, Comply

43 BeneCo s Webinars Topic Date Time ACA: Creating a Safe Harbor Medical Plan to Immunize You Plan From Penalties 6/10/ :30-11:30 Strategic Rx Spend Management 7/15/ :30-11:30 When Does it Make Sense For My Plan to Pay Penalties? 8/12/ :30-11:30 To Register: ACA 2015: Ready, Set, Comply

44 Short videos on benefits topics of the week. Delivered once per week Examples: Wellness and the EEOC What to do about Seasonal Employees? Private Exchanges Stoploss Contracts and Coverage under the Stability Period BeneCo s Strategy Minutes Check out our website for the most recent and archived versions ACA 2015: Ready, Set, Comply

45 ACA Impact Study ACA Impact Study How will ACA impact my organization? What do I need to plan for? Free initial consultation Fee for service basis based on plan complexity ACA Sustainability Analysis How do I create a long term sustainable ACA cost strategy and still comply? Fee for service basis based on plan complexity -45- ACA 2015: Ready, Set, Comply

46 Ask us about Haiti The work: Orphan care and sponsorship, tent city refugee relocation and community development, microenterprise other ministry opportunities To get more info or engage in some way, drip us an , or to get a glimpse of the work got to or ACA 2015: Ready, Set, Comply

47 For Follow up Information or Questions Jeff Schultz Vice President BeneCo of Wisconsin ext 112 Justin Andaloro Manager of Marketing & Communications BeneCo of Wisconsin ext 114 To Register for upcoming webinars: ACA 2015: Ready, Set, Comply

48 Questions? -48- ACA 2015: Ready, Set, Comply