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Alleviating HR’s ACA Headaches
August 13, 2015
Lyndsey Barnett, Esq.Graydon Head & Ritchey
LLP
Affordable Care Act
Where We Are At&
Where We Are Still Going
What Has Occurred Dependent age 26 mandate
Opening of exchanges Expansion of Medicaid
Community rating
Employer MandateIndividual Mandate
Small business tax credits
Elimination of preexisting conditions
Early retiree subsidies
Free preventive services Cost sharing rules
Reporting
• Applies to all large employers and to all self-funded employers
• First reports are due in 2016 for 2015
• IRS Forms 1094 and 1095
Reporting Deadlines
• Forms due to employees – January 31
• Forms due to IRS if submitted electronically – March 31
• Forms due to IRS if submitted in paper (only permissible if fewer than 250 returns) – February 28
Reporting – Large Employers
• Number of FT employees by month
• Number of total employees by month
• Employees share of lowest cost premium
• Whether employee was offered coverage, was it minimum value and affordable
Reporting – Self-Funded Employers
• Name, address and SSN of covered employees, spouses and dependents
• Months of coverage for each individual
• General employer information
Cadillac Tax
40% Excise Tax
Effective in 2018
Cadillac Tax – Excess Contributions
• Single Coverage - $10,200
• All other tiers - $27,500
• Indexed based on medical inflation
• Age and gender adjustments
• Employment status adjustments
Cadillac Tax – Subject to Tax
Employer & Employee Premium
Contributions to Health Plans
Contributions to FSAs, HSAs and
HRAs
On-Site Clinics, EAP & Wellness Programs
Cadillac Tax – Not Subject to Tax
Limited scope dental and
vision benefits
Long-term care
insurance
Accident or disability insurance
Liability or automobile
medical payment insurance
Workers’ compensation
Who Are Your Full-Time Employees?
Full-Time Employee
• An employee who works an average of 30 or more hours per week
• An employee who works an average of 130 or more hours per month
10/15/13 10/15/1510/15/14 10/15/16 12/31/171/1/171/1/15 1/1/16
Measurement
Measurement
Measurement
Stability
Stability
Stability
= Administrative Period
Lookback Method
Your Definition
401(K) Dental
Life LTDPTO
How it Impacts the HR Function
New Hire Process
Waiting Period
Seasonal
Leaves of Absence
Nonpayment of Premium
Termination
COBRA
Action Items
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