ACA Reporting RequirementsWho, What, When?

July 14, 2015

Presenters

Stew BeltzDirector, Health & Welfare Benefits

Todd IngvesDirector, Information Management

Agenda

• Reporting requirements overview

• Who reports?

• What to report?

• When to report?

• Preparing to report

• If you do not report

• Resources

Reporting Requirements Overview

• Report member’s healthcare coverage

• Required for compliance with key ACA components:

• Individual mandate

• Employer mandate

• Qualification for exchange subsidy

Reporting to the IRS and Individuals

Reporting Requirements Overview

• Individual mandate: Must maintain minimum essential coverage for self and dependents

• Employer mandate: Large employers must offer

• Minimum essential coverage to 95% of full-time employees and dependents (70% in 2015) and

• Affordable coverage providing minimum value to full-time employees and dependents

Review of Mandates

Reporting Requirements Overview

• Health plans report individual coverage for individual mandate purposes

• Use Forms 1094-B and 1095-B

• Large employers provide information for government to enforce employer mandate and verify individual’s eligibility for premium tax credits

• Use Forms 1094-C and 1095-C

Section 6055 Requires Section 6056 Requires

Who Reports

• Health insurance carriers (and HMOs)

• Group health plan sponsors (e.g., church plans -- the Board)

• You, if you are an Applicable Large Employer (ALE)

Health Plans Large Employers

Who Reports

• Essentially same criteria as used to determine the 50-FTE threshold for ACA employer mandate

• ALE = employs on average 50 or > full-time employees

• Full-time employee = employee employed on average 30 or > hrs/wk

• Full-time equivalent employee = combination of employees, each of whom individually is not a full-time employee, but who, in combination, are equivalent to a full-time employee

Applicable Large Employer Criteria

See pensions.org/healthcarereform for ACA-related resources!

What Is an Aggregated ALE Group?

• Employer Identification Number (EIN) or Federal Tax Identification Number (TIN) is shared by more than one organization; or

• 80% or more of an employer’s operating funds are provided by a different organization and there is common management between the organizations; or

• 80% or more of the members of the governing body of an organization are either representatives of, directly or indirectly control, or are controlled by another organization.

What To Report

• Reporting involves filing information with the IRS and disclosure to individuals

• IRS filing:

• Includes individual information and transmittal form

• May be done electronically or by paper (if more than 250 forms, must submit electronically)

What To Report

• Form 1094-B: Transmittal of Health Coverage Information Returns

• Form 1095-B: Health Coverage

• Employee statement

Board of Pensions

What To Report

The Board will provide standard IRS identifying information.

What To ReportThe Board will provide standard IRS identifying information for all parties.

What To Report

• Form 1094-C: Transmittal form or cover sheet that contains summary information to accompany Form 1095-C

• Form 1095-C: Detailed form naming each employee being reported

• Employee statement

Large Employer

What To Report1094-C Transmittal Form: Summary from each employer, Part I

Each Applicable Large Employer provides information identifying each reporting entity, as applicable.

What To Report1094-C Transmittal Form: Summary from each employer, Part II

ALE completes this part to tell IRS if:

1) This is the final set of data

2) Report is specific to 1 employer or set of employers

3) An eligible reporting method is being used

What To Report1094-C Transmittal Form: Summary from each employer, Parts III & IV

Part III provides a month-by-month summary of minimum essential coverage offered to full-time employees and dependents

Part IV identifies to the IRS any other affiliated

employers under the IRS “Controlled Group” rules

What To Report1095-C Form: Provides detail on each full-time employee, Parts I & II

Part I: Basic employee tax information, similar to Form 1099

Part II: Confirms whether the employee was offered affordable coverage that meets minimum value requirements

What To Report1095-C Form: Provides detail on each full-time employee, Parts III

Skip Part III of Form 1095-C!

The Board reports member and dependent details in its forms.

What To ReportEmployee Statement

Each employee must receive a copy of the Form 1095-C that you submit to the IRS on their behalf

When To Report

Deadline Type Deadline Date*

Statement to employees

Paper IRS report

Electronic IRS report

Annual reporting requirements start in early 2016 for coverage provided in 2015

*Same as for W-2s

Preparing To Report

• Determine size of employer on an Aggregated ALE Group basis

• Decide who has data and who will prepare the report

• Is data available month-by-month?

• Is data available employer-by-employer?

• Is third-party reporting an option?

Large Employer Should Begin Now

If You Do Not Report

• Failure to file and/or furnish statement are each subject to a penalty of:

• $100 per form/statement

• Up to $1.5 million

• Subject to reductions for corrections and other adjustments

• For 2015, no penalty will apply if good faith effort to comply can be demonstrated

Board Resources

• ACA requirements summary, by year

• Preparing for the Employer Mandate

• Worksheet To Determine Total Employee Count

• Additional resources and links

pensions.org/healthcarereform

IRS Resources

• irs.gov/aca

• irs.gov

• Internal Revenue Code Sections 6055, 6056 & 4980H

• Forms 1094-B, 1095-B, 1094-C & 1094-C (including instructions and questions and answers)

• Information Reporting by Applicable Large Employers

• Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters (Publication 5165)

• Understanding employer reporting requirements of the health care law

• IRS Controlled and Affiliate Service Groups

Questions?