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© 2015 Texas Association of School Boards, Inc. All rights reserved.
Affordable Care Act (ACA)Reporting Requirements
Holly Murphy
Senior Attorney, TASB Legal Services
July 16, 2015
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Overview
How reporting applies to your district
Form 1095-C
Form 1094-C
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Forms
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)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
Page 1 of instructions:
Purpose of Form
Even if you fully comply with ACA, you must report
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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-
time
employees*
Form 1095-C for each full-
time employee
- Form 1095-C for each full-
time employee
AND
-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)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
TRS-ActiveCare
PPOs: “self-funded multiple employer plans”
HMOs: fully-funded plans
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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-
time
employees*
Form 1095-C for each full-
time employee
- Form 1095-C for each full-
time employee
AND
-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)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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-
time
employees*
Form 1095-C for each full-
time employee
- Form 1095-C for each full-
time employee
AND
-Form 1095-C for each
employee who was not full-
time but who enrolled in
coverage
Which Districts Must Report
* Including workforce extender (full-time equivalents as defined by ACA)
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)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Calendar Year
Reporting Period
Even if your district has a non-calendar year plan
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Reporting Deadlines
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Reporting Deadlines
January 31: statements to employees(February 1 for 2016)
Page 3 of instructions: Furnishing Forms 1095-C to Employees
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Reporting Deadlines
28
February 28: reports to IRS if filing on paper(February 29 for 2016)
Page 2 of instructions: When to File
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
1095-C: Employee Information
Voluntary for 2014!
Page 1 of instructions: Reminders
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Part I
Part II
Part III
Three Parts
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
Page 1 of instructions: Who Must File (first paragraph)
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Employee and district information
Part I
Page 6 of instructions: Part I
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Offer of coverage and cost
Part II
Pages 6-7 of instructions: Part II –Employee O0ffer of Coverage
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Whether employee and/or family was eligible for coverage – Series 1 codes
Line 14
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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.
Page 7 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
Page 7 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Net cost to employee for lowest-cost, employee-only coverage.
Line 15
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Only if code 1B, 1C, 1D, or 1E was checked on Line 14
Line 15
Page 7 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Safe Harbors and other relief–series 2 codes
Line 16
Pages 7-8 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
Page 8 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Only for self-insured plans
ActiveCare: PPOs
Part III: Enrollment Reporting
Pages 8-9 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Part III
For each covered individual
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Employer TRS
Designating TRS for Enrollment Reporting
District leaves 1095-C, Part III blank
TRS will report on 1095-B
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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-
time
employees
- Form 1095-C for
each full-time
employee
- Parts I and II
only
- Form 1095-C for each full-time
employee
- Parts I and II
- Part III if employee enrolled in
self-insured coverage
AND
-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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
1094-C: Employer Information
Voluntary for 2014!
Page 1 of instructions: Reminders
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Four Parts
Part I
Part II
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Four Parts
Part III
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Four Parts
Part III
Part I
Part IV
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Coversheet for 1095-C
• One Form 1094-C with each batch of 1095-Cs filed with the IRS
1095-C 1095-C1095-C
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Part I
District information
© 2015 Texas Association of School Boards, Inc. All rights reserved.
“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
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Authoritative Transmittal
• One 1095-C is designated an Authoritative Transmittal
• The Authoritative Transmittal includes aggregate, employer-level
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
Page 4 of instructions: Part II – ALE Member Information, Line 19
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Line 22: Certifications of Eligibility
Check each applicable box
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Certifications of Eligibility
• Qualifying Offer Method
• Qualifying Offer Method Transition Relief
• Section 4980H Transition Relief
• 98% Offer Method
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Only on Authoritative Transmittal
Part III
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Column a: Substantial Compliance
Pages 5 and 12 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Column b: Full-Time Employee Count
Page 6 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Column c: Total Employee Count
Page 6 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Column d: Aggregate Group Indicator
Page 7 of instructions
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Column e: Section 4980H Relief
Page 6 of instructions
Code A or Code B
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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
* Including workforce extender (full-time equivalents as defined by ACA)
Page 5 of instructions: Section 4980H Transition Relief; page 13
Code B
Code A
© 2015 Texas Association of School Boards, Inc. All rights reserved.
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?
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Questions?
© 2015 Texas Association of School Boards, Inc. All rights reserved.
Affordable Care ActReporting Requirements
Thank you!