By now most businesses and insurance companies are familiar with the Patient Protection and Affordable Care Act (PPACA), sometimes referred to as ACA or ObamaCare. In 2016 (for reporting on calendar year 2015) employers and insurers are expected to be compliant with ACA reporting requirements.
Understanding all of the rules associated with the Affordable Care Act can be confusing. Janice Krueger, from Greatland helps explain everything you need to know about ACA reporting and filing Form 1095-B or Form 1095-C, and applicable 1094 forms for the 2015 reporting year
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Affordable Care Act Mandates
Individual
• Each individual must have minimum essential healthcare coverage or qualify for an exemption or pay a
penalty (Individual Shared Responsibility Payment)
Employer
• Employers with at least 50 FT employees (including FT equivalents) must offer affordable minimum
essential coverage (MEC). If at least one of its FT employees receives a premium tax credit, the employer
may be subject to a penalty (Employer Shared Responsibility Payment)
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Affordable Care Act Definitions
• Full-Time Employee
• Averaged at least 30 hours per week for a calendar month or
• 130 service hours in a calendar month
• Full-Time Equivalent (FTE) Employee
• A combination of employees, each of whom is not treated as a full-time
employee, but in combination are counted as the equivalent of a full-time employee.
• Applicable Large Employer (ALE)
• An employer that employed an average of at least 50 FTEs during the preceding calendar year (2014)
• ACA reporting is a moving target!
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Who Needs to File?
1. Applicable Large Employer (ALE)
• Employers with at least 50 FTEs
2. Self-Insured Employers
• Regardless of the number of FTEs
3. Healthcare Insurers
Internal Revenue Code (IRC) Sections 6055 and 6056
outline the requirements for 1095-B and 1095-C reporting.
Do you have more than 50
full-time employees (FTEs)?
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Polling Question
• How many clients do you have with at least 50 FTEs?
A. Less than 25
B. Between 25-50
C. More than 50
D. I don’t know
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ACA Filing Requirements
• The Big Two:
1. Send copies to recipients/employees
2. File to IRS
• 250 E-file threshold
• The Forms:
A. 1095-A (Exchange)
B. 1095-B & 1094-B
C. 1095-C & 1094-C
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1095-B Key Points
• Information return filed by Healthcare Insurers and/or Self-Insuring Employers with less than 50 FTEs
• 1094-B – Transmittal to IRS
• Line 8 – Origin of Policy:
• A – Small Business Health Options Program (SHOP)
• B – Employer-sponsored coverage
• C – Government-sponsored program
• D – Individual market insurance
• E – Multiemployer plan
• F – Other designated MEC
• Line 9 – SHOP identifier should be left blank for 2015
• If a self-insured employer is filing Form 1095-B, Part II should be left blank and Part III should include the self-insured employer’s
information
• “Self-Insured = Provider”
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1095-C Key Points
• Information return filed by Applicable Large Employers
• 1094-C – Transmittal to IRS
• For each FT employee of an employer, there must be only one 1095-C filed
• Part II vs. Part III
• Part II is about the offer of coverage
• Part III is about the coverage that was supplied
• Part II
• “Plan Start Month” is optional for 2015
• “All 12 Months” vs. Individual Monthly boxes
• Use one or the other, not both for the same line
• It is acceptable to use “All 12 Months” on one line and month-by-month on another
• Part III
• Only completed if the employer is self-insured
• If entering data in Part III, employee entered on Line 1 must be included
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Lines 14-16 Codes (1095-C)
• A whole webinar in itself
• Decoding the codes!
• Line 14
• 1A – Qualifying Offer: MEC providing MV offered to FT employee 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 & dependents
• 1B – MEC providing MV offered to employee only
• 1C – MEC providing MV offered to employee and at least MEC to dependents (not spouse)
• 1D – MEC providing MV offered to employee and at least MEC to spouse (not dependents)
• 1E – MEC providing MV offered to employee and at least MEC to spouse and dependents
• 1F – MEC NOT providing MV
• 1G – Coverage offered to a non full-time employee who enrolled in self-insured coverage for one or more months
• 1H – No offer of coverage
• 1I – Qualifying Offer Transition Relief 2015
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Lines 14-16 Codes (1095-C)
• Line 15
• Enter amount of the employee share of the lowest-cost monthly premium for self-only MEC providing MV that is offered to employee; include cents
• Line 16
• 2A – Employee is not employed on any day during the month
• 2B – Employee is not a FT employee
• 2C – Employee enrolled in coverage offered
• 2D – Employee is in a 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
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Covered Individuals
• Enter names of those individuals enrolled in coverage
• Check monthly box if individual was covered at least one day during the month
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Polling Question
• How many self-insured clients do you represent?
A. Less than 25
B. Between 25-50
C. More than 50
D. I don’t know
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Filing Deadlines
Due Date Requirements
February 1, 2016 Form 1095 copies to Recipients/Employees
February 29, 2016 Paper copies of Form 1095/1094 to IRS
March 31, 2016 E-file Form 1095/1094 to IRS
*Due dates represent 2015 calendar year reporting
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Penalties
In 2016 (for reporting on calendar year 2015) employers and insurers are expected to be compliant with ACA reporting requirements.
• Penalties apply for:
• Failure to file
• Failure to furnish recipient statements
• Failure to file timely
• Failure to file electronically when required to do so
• Section 4980H(a) & (b) penalties for employers with 100+ FTEs in 2014
• Incorrect filings will not be penalized for calendar year 2015 filing (reported in 2016) if employers/insurers make a good faith effort to
comply
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Penalties
Beginning January 1, 2016, Internal Revenue Code (IRC) section 6721 imposes a:
• $50 per information return if you correctly file within 30 days of the due date.
• $100 per information return if you correctly file more than 30 days after the due date but by August 1.
• $250 per information return if you file after August 1 or you do not file required information returns.
Maximum penalties to employer/healthcare insurer for failure to file correct information returns:
• $3 million/year ($1 million for small businesses)
• $500 per return for intentional disregard with no maximum penalty
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Filing Options
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About Greatland
• Over 40 Years in Business
• 135 Employees + additional seasonal staff
• Specialize in W2/1099/1095 – Wage, Income and Information Reporting
• Federal
• State
• Recipient Print and Mail
• Team of full-time compliance experts
• Support: Phone|Chat|Email + Extended Hours
• Security – SSAE 16 SOC II
We work hard to develop secure, compliance-driven products on the
frontend and excellent, industry-leading support on the backend.
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About Yearli - Simple five-step process
1. Create Account Online or Purchase & Install Software
2. Import or Enter Data
3. Complete Transmittal (If Applicable)
4. Edit and/or Review Data
5. Submit – E-File to IRS and Mail copies to recipients/employees
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Electronic Filing Comparison
• Software vs. Online Filing
• Chat, Email, Phone Support + Extended Hours
• Print and Mail Service
• Filing Fees - Calculator
• Data Entry or Import
• À la carte options
• Many Printing Options
• Additional Form Types
• Full 94X Library
• 80 State Forms
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Polling Question
• Have you determined your ACA filing process for this year?
A. Yes, I have a solution.
B. No, I do not have a solution yet
C. I do not need an ACA reporting solution for 2015 reporting
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Questions?