Employer Reporting under the ACA - efgmbenefits.com Reporting... · Section 6055 Reporting...

Employer Reporting under the ACA

Suzanne Spradley, SVP, Sr. Counsel, Legal & Compliance Chase Cannon, VP, Counsel, Legal and Compliance

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Employer Mandate Basics

Applicable large employers must offer minimum essential coverage (MEC) that is affordable and meets minimum value standards to FTEs and their dependent children up to age 26.

Employer Size

Effective for plans beginning in 2015

2016 plan years and beyond

50 – 99 FTEs *including FT equivalents

Possible delay if employer: • Maintains workforce size • Maintains coverage

1. 95% of dollar amount or 2. Same % of contribution

• Certifies on Form 6056

Employer must offer coverage to 95% of FTEs

*not including FT equivalents

100+ FTEs *including FT equivalents





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Employer Mandate - Penalty B

Minimum Value – The plan must pay on average at least 60% of allowable costs for all covered services on an aggregate basis.

Affordable - The employee’s required deduction for single only coverage for the least expensive plan the employer offers that meets the 60% Minimum Value threshold cannot exceed 9.5% of employee’s wages.

There are three affordability safe harbors

Certified on Form 1095-C

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Penalty Amounts

Penalty A

$2,000 times each full-time employee Minus the first 30 employees (80 in 2015)

Penalty B

$3,000 times each full-time employee who receives a premium tax credit

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Section 6055/6056 Employer Reporting

Penalty Assessment: Reporting Cycle

Individual Goes to Exchange Exchange to HHS Exchange to Employer

HHS to IRS IRS collects 1040 IRS collects ER Report

IRS IRS to Individual IRS to Employer

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Employer Reporting Overview

6055 Enforce individual

mandate

Insurers

Self-insured Plans

Forms 1094-B, 1095-B filed by

insurers and SG self-insured plans

6056 Enforce employer

mandate

Applicable large employers

Members of a ALE control group

Forms 1094-C and 1095-C filed by

employers and LG self-insured plans

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6055 Reporting

Section 6055 Reporting

Reporting by any entity that provides:

minimum essential coverage (MEC)

to individuals enrolled during a calendar year

Information is used for purposes of the individual mandate

Type of Plan Who Files Report Which Forms

Insured Plan Insurance Carrier Forms 1094-B & 1095-B

Self-Insured Plan 1 – 49 FTEs

Employer Forms 1094-B & 1095-B

Self Insured Plan 50+ FTEs* Or member of control group that is 50+ FTEs

Employer Form 1095-C, Part III

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6056 Reporting

Section 6056

Reporting by:

an applicable large employer (ALE) or member of a control group that is an ALE

on group health coverage whether or not offered to

full-time employees

whether or not full-time employee is enrolled

Information is used to determine:

employer’s compliance with employer mandate

Individual’s qualification for premium tax credit

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Question: Employer Mandate Delay for Employers with 50-99 FTEs

Question: What if my company qualifies for transition relief from the employer mandate until 2016. Do I still need to report for purposes of 2015?

Answer: The transition relief does not delay the 2015 employer reporting obligations. You must submit Forms 1095-B and 1095-C covering 2015 data, which are due in 2016.

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Which Forms must be filed for 6056 ALE reporting?

Form 1094-C

Transmittal Form Generally one per FEIN Control Group information Compliance with Penalty A threshold

Form 1095-C

Employee Statement One for each FTE Compliance with Penalty B affordability threshold Information on coverage offered / not offered If self-insured, information on individuals enrolled

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When are the Forms Due?

To Employees

Jan 31st (or Feb. 1 in 2016)

To IRS

Feb. 28 if paper filing Mar. 31 if electronic filing

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Form 1095-C: Delivery to Employee

Mail Paper Forms to Last Known Address

• Could be combined with Form W-2 mailing

Electronic Delivery

• Must obtain affirmative consent

Hand Delivery

• Signature of receipt recommended

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Question: Filing Electronically

Question: How do we file electronically?

Answer: The Affordable Care Act Information Returns (AIR) may be electronically filed

by completing an e-services registration on: https://la1.www4.irs.gov/e- services/Registration/Reg_Online/Reg_RegisterUserForm

The IRS will issue registration confirmation code through U.S. Postal Service

Use the confirmation code to login within 28 days

May contract with a vendor on your behalf

Publication 5165: http://www.irs.gov/PUP/for_taxpros/software_developers/information_returns/ Draft_Pub_5165_04_2015.pdf

https://la1.www4.irs.gov/e-services/Registration/Reg_Online/Reg_RegisterUserForm



http://www.irs.gov/PUP/for_taxpros/software_developers/information_returns/Draft_Pub_5165_04_2015.pdf



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Data Required for Reporting

ALE Member Information

Address, EIN, etc. # of FTEs # of all employees

Controlled Group Information

Names of CG members EINs of CG members # of FTEs for each member

Employee Information

Names, address, etc. SSNs of EE and dependents Months as FTE Months in waiting period / initial measurement period

Offer of Coverage Information

Minimum value? Affordable? Cost of self-only tier Offer made to spouse / child MEC offered to 70%/95% of FTEs?

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Question: Payroll Vendor Assistance on Reporting

Question: Will my payroll company handle this for me? If not, who is responsible for filling out these forms?

Answer: The employer is responsible for filling out Form 1094-C and 1095-C if the employer is an applicable large employer (ALE) or a member of a control group that is an ALE. Many payroll companies have a employer reporting module that you can purchase as do benefit administration companies. There are also stand-alone vendors.

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Question: Consequences for Noncompliance

Question: What if I don’t comply with Section 6056?

Answer: • Failure to comply with Section 6056 reporting may result in:

• $250 per failure (per return) • Intentional disregard = $500 per failure • For 2015 only - no penalty for good faith effort

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Section 6056 Reporting: Getting into the details

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Form 1094-C Transmittal

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NOTICE

Notice

These 2015 forms and instructions are draft versions only and should not be relied upon for filing. The IRS may make changes prior to releasing final 2015 versions.

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Form 1094-C Overview

Form 1094-C is cover letter for 1095-C employee statements

Identifies employer and provides information about affiliates (control group members)

A third party or affiliate may assist an ALE member with reporting:

However, the ALE member cannot transfer its potential liability for failure to report.

Except, a government entity may be designated to file for another governmental unit (“Designated Government Entity (DGE)”).

DGE must file a separate Form 1094-C for each ALE member for which the DGE is reporting.

On lines 9-13 of Form 1094-C, Part I, the DGE would report its name, address and EIN and on lines 1-8 the name, address, and EIN of the ALE member for which it is reporting.

Answers the question of whether the employer met Penalty A threshold (70% / 95% of FTEs offered coverage)

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DRAFT AS O Jun 16, 2015

DO NOT FIL

Draft Form 1094-C Part I - Employer Information

Form1094-C Department of the Treasury Internal Revenue Service

Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns

▶ Information about Form 1094-C and its separate instructions is at www.irs.gov/f1094c. FCORRECTED

120116

OMB No. 1545-2251

2015

Part I Applicable Large Employer Member (ALE Memb er) 1 Name of ALE Member (Employer) 2 Employer identification number (EIN)

3 Street address (including room or suite no.)

DGE

4 City or town 5 State or province 6 Country and ZIP or foreign postal code

7 Name of person to contact 8 Contact telephone number

9 Name of Designated Government Entity (only if applicable) 10 Employer identification number (EIN)

11 Street address (including room or suite no.)

12 City or town 13 State or province 14 Country and ZIP or foreign postal code

For Official Use Only

15 Name of person to contact 16 Contact telephone number

17 Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

18 Total number of Forms 1095-C submitted with this transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶

19 Is this the authoritative transmittal for this ALE Member? If “Yes,” check the box and continue. If “No,” see instructions . . . . . . . . . . . . . . . .

20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member . . . . . . . . . . . . . . . . . . . . . . . . . . ▶

21 Is ALE Member a member of an Aggregated ALE Group? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

If “No,” do not complete Part IV.

22 Certifications of Eligibility (select all that apply):

A. Qualifying Offer Method B. Qualifying Offer Method Transition Relief C. Section 4980H Transition Relief D. 98% Offer Method

Under penalties of perjury, I declare that I have examined this return and accompanying documents, and to the best of my knowledge and belief, they are true, correct, and complete.

http://www.irs.gov/f1094c

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▲

▲

Signature Title Date

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61571A Form 1094-C (2015)

▲

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Example

Facts: Joe Smith owns a restaurant with 70 full-time employees (including full-time equivalents) and a dry cleaner with 10 full-time employees.

Question: Can the companies combine information into one Form 1094-C ?

Answer: No. Members of a controlled group have separate reporting responsibilities and cannot combine their information into one Form. Each member must file a separate Form 1094-C.

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▲

▲

Draft Form 1094-C Part I – Authoritative Transmittal Information

18 Total number of Forms 1095-C submitted with this transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶

19 Is this the authoritative transmittal for this ALE Member? If “Yes,” check the box and continue. If “No,” see instructions . . . . . . . . . . . . . . . .

20 Total number of Forms 1095-C filed by and/or on behalf of ALE Member . . . . . . . . . . . . . . . . . . . . . . . . . . ▶

21 Is ALE Member a member of an Aggregated ALE Group? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

If “No,” do not complete Part IV.

22 Certifications of Eligibility (select all that apply):

A. Qualifying Offer Method B. Qualifying Offer Method Transition Relief C. Section 4980H Transition Relief D. 98% Offer Method

Under penalties of perjury, I declare that I have examined this return and accompanying documents, and to the best of my knowledge and belief, they are true, correct, and complete.

Signature Title Date

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions. Cat. No. 61571A Form 1094-C (2015)

6 Country and ZIP or foreign postal code

10 Employer identification number (EIN)

14 Country and ZIP or foreign postal code

A T A O

e

▲


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Question 1: Authoritative Transmittal

Question: If my company is a part of a control group and the parent company is filing the Form 1094-C on our behalf, should they check the box for the authoritative transmittal?

Answer: Yes. Each member of a control group will have a separate Form 1094-C associated with their EIN, and which will be the authoritative transmittal for that company.

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Question 2: Authoritative Transmittal

Question: When would a company not check the box for the authoritative transmittal?

Answer: A company may choose to file multiple Form 1094-C s and then it must aggregate its data on one Form 1094-C as the authoritative transmittal. For example, there are three divisions in a company. Each division fills out its own Form 1094-C and attaches it to the associated Form 1095-Cs for its employees. One of the Forms must aggregate the data for all three divisions and check the box as the authoritative transmittal. The other two divisions would not check the box.

DRAFT AS OF

DO NOT FILE

Form 1094-C Transmittal, Page 2

120216 Form 1094-C (2015) Page 2 Part III ALE Member Information—Monthly

(a) Minimum Essential Coverage Offer Indicator (b) Full-Time Employee Count

for ALE Member (c) Total Employee Count

for ALE Member (d) Aggregated Group Indicator

(e) Section 4980H Transition Relief Indicator

23 All 12 Months

Yes JuNo ne 16, (2a) 0Min1imu5m Essential Coverage

24 Jan

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec

Yes if 70% (95% 2016+) of FTEs and dependents were offered MEC that month

Don’t count employees in

non-assessment period

Check “yes” in 2015 for non- calendar year plan transition relief months

Form 1094-C (2015)

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DRAFT AS OF

28 May







23 All 12 Months

Yes JuNo ne 16, 2015 (c) # of All

24 Jan

(b25) # oFfeb FTEs 26 Mar

DO NOT FILE Employees

Include part-

time and

Do not short-term 27 Apr

include employees

29 in nJuone n- 30 assJeulyssment

period

employees

Use first or last day of month

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec

Form 1094-C (2015)

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DRAFT AS OF June 16, 2015







23 All 12 Months

24 Jan

25 Feb

26 Mar

27 Apr

28 May

29 June

30 July

31 Aug

32 Sept

33 Oct

34 Nov

35 Dec

Yes No

(d) Aggregate

DOGroNup InOdicatTor FILE Check the

box if your company is part of a control group

Form 1094-C (2015)

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Form 1094-C Transmittal, Page 3 DRAFT AS OF

120315

Form 1094-C (2015) Page 3 Part IV Other ALE Members of Aggregated ALE Group Enter the names and EINs of Other ALE Members of the Aggregated ALE Group (who were members at any time during the calendar year).

36 June 1651

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, 2015 FILE

Name EIN Name EIN

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Part IV: Other ALE Members of Aggregated ALE Group

If your company is a member of a control

group, enter names and EINs of affiliates If ALE is not a member of a control group,

then ignore this section

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Form 1094-C (2015)

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Alternative (Simplified) Reporting Methods

* Must still complete 1095-C for IRS

Most employers will not use one of these methods

Qualifying Offer Method

EE receives qualifying offer for all months Qualifying offer- MV, FPL safe harbor Skip Line 15, 1095- C (cost) May provide general statement to EE’s rather than 1095-C *

Qualifying Offer Transition Relief

Employer certifies it may a qualifying offer to 95% of FT EE’s even if not all 12 months Same as to the left *

Section 4980H Transition Relief

Employers with 50 to 99 FTE’s

98% Offer Method

For all 12 months, employer offered 98% of EE’s affordable, MV MEC to EEs and dependents Skip identification and count of FT EE’s on 1094-C

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Form 1095-C Employee Information

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Purpose of 1095-C Form

Parts I and II:

Whether or not the employer owes a Penalty B for a specific employee for a specific month

Whether the employee potentially qualifies for a premium tax credit

Part III (self-insured only):

Used by the employee when they file their income taxes to prove the employee (and dependents / spouse) maintained “minimum essential coverage”

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Question: Forms Received by Employee

Question:

If my company is fully-insured, will the employer send the Form 1095-C to the employee or is the employer responsible for sending the Form 1095-C?

Answer:

If the employer is fully-insured, the insurance carrier will provide this information via Form 1095-B and the employer will provide the information via Form 1095-C so employees may be receiving two forms.

Remember: if the employer is self-insured, the information will be combined on one Form 1095-C.

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Steps to Complete Form 1095-C

Identify every employee who was full-time during 2015 and identify status for each month:

Employed (or not) for each month

Enrolled in coverage (or not) for each month

In a limited non-assessment period for each month

If self-insured, identify every non-FT individual enrolled in plan

Identify the type of coverage offered to the employee, the employee’s dependent(s)

and the employee’s spouse

MEC

Minimum Value or

No Offer

Know the cost of the least expensive, self-only MV coverage offered to that employee

Identify which affordability tests you used to determine if the coverage is affordable for each employee

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Key Term: Limited Non-Assessment Period

Only if EE is offered MV coverage by first day of month after limited non-assessment period:

Jan. – Mar. of first year as an ALE

Waiting period if employee is measured monthly

Waiting period if use the look-back method for EE classification

Initial measurement period and admin. period

Period following change in status

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DRAFT AS OF

Form 1095-C: Part II, Line 14: Offer of Coverage

Form 1095-C Department of the Treasury Internal Revenue Service

Employer-Provided Health Insurance Offer and Coverage ▶ Information about Form 1095-C and its separate instructions is at www.irs.gov/f1095c.

VOID

CORRECTED

600116 OMB No. 1545-2251

2015 Part I Employee 1 Name of employee 2 Social security number (SSN)

Applicable Large Employer Member (Employer) 7 Name of employer 8 Employer identification number (EIN)

3 Street address (including apartment no.) 9 Street address (including room or suite no.) 10 Contact telephone number

4 City or town 5 State or province 6 Country and ZIP or foreign postal code 11 City or town 12 State or province 13 Country and ZIP or foreign postal code

Part II Employee Offer and Coverage Plan Start Month (Enter 2-digit number):

14 Offer of August 6, 2015

All 12 Months Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec

Coverage (enter required code)

15 Employee Share of Lowest Cost Monthly Premium, for Self-Only Minimum Value DO NOT FILE Coverage $ $ $ $ $ $ $ $ $ $ $ $ $ 16 Applicable Section 4980H Safe Harbor (enter code, if applicable)

Part III Covered Individuals


Form 1095-C Line 14 Indicator Codes

• Qualifying offer was provided for all 12 months (MEC/MV; FPL safe harbor) 1A

• MEC/MV offered (ever day of the month) to employee only 1B

1C • MEC/MV offered to employee; MEC offered to dependents but not spouse

• MEC/MV offered to employee; MEC offered to spouse but not dependents 1D

• MEC/MV offered to employee; MEC offered to spouse and dependents 1E

• MEC not providing MV offered to employee (i.e., skinny plan) 1F

• MEC offered by self-insured plan to employee who is not full-time / enrolled 1G

1H • No offer of MEC

• Qualifying Offer Transition Relief 1I

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DRAFT AS OF




VOID

CORRECTED

600116 OMB No. 1545-2251












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Form 1095-C: Part II, Line 15: Employee Contribution Report lowest contribution for self-only MV coverage

Regardless of what tier of coverage employee is enrolled

If same in all 12 months, only enter once

Only fill out line 15 if MV was offered (otherwise affordability is a nonissue) :

One of the following codes was used on line 14:

1B: MV offered to EE only

1C: MV offered to EE and dependents

1D: MV offered to EE and spouse

1E: MV offered to EE, spouse and dependents

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DRAFT AS OF




VOID

CORRECTED

600116 OMB No. 1545-2251












Form 1095-C Line 16 Indicator Codes

2A • Employee was not employed any day during the month

2B • Employee was employed, but not FT

2C • Employee enrolled in coverage offered by employer (if applicable, trumps all)

2D • Employee was in limited non-assessment period

2E • Employer pays fee to union pursuant to a CBA

2F • Employee waived coverage that was affordable coverage based on W-2 safe harbor 2G

• Employee waived coverage that was affordable coverage based on FPL safe harbor 2H •

Employee waived coverage that was affordable based on Rate of Pay safe harbor

2I • Non-calendar year transition relief applies for month

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Affordability Safe Harbors

Form W-2

• Box 1 • Retrospective in

application

Rate of Pay

• Hourly rate x 130 hours; or

• Monthly salary

Federal Poverty Line

• Based on 100% FPL • 2015, $93.17/mo

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Example: New Full-time Employee Enrolls in Plan

Facts: Full-time employee was hired on March 28th

Waiting period is 1st of Month following 60 days Employee enrolls in plan

1H: No offer of coverage 1E: MEC/ MV offered to EE; MEC offered to Dep. And Spouse

2A: Not employed any day of month 2D: Limited non-assessment period 2C: Enrolled in the plan

1H 1H 1H 1H 1H 1E 1E 1E 1E 1E

148

2A 2A 2D 2D 2D 2C 2C 2C 2C 2C 2C 2C

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Example: New Full-time Employee Declines Affordable MEC

Facts: Full-time employee was hired on March 28th

Waiting period is 1st of Month following 60 days Employee waives enrollment

1H: No offer of coverage 1E: MEC/ MV to EE; MEC to Dep.

2A: Not employed any day of month 2D: Non-assessment period 2H: Offer meets Rate of Pay Safe Harbor

1H 1H 1H 1H 1H 1E 1E 1E 1E 1E 1E 1E

148

2A 2A 2D 2D 2D 2H 2H 2H 2H 2H 2H 2H

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Question: Mid-month Termination

Question: How do I report the month that an employee terminates employment if coverage ends on date of termination?

Answer: Remember that you report that an employee was offered coverage for a month under Part II of Form 1095-C only if the employee could be covered for all days of the calendar month. Enter code 1H, No offer of coverage, on line 14.

If the coverage would have continued if the employee had not terminated employment during the month, you will be eligible for relief from the employer mandate penalties. Enter code 2B, on line 16 for that month.

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Example: New Full-time Employee Declines Affordable MEC

Facts: Full-time employee was terminated on August 17th

Coverage ended on August 17th (COBRA not elected)

1H: No offer of coverage 1E: MEC/ MV to EE; MEC to Dep.

2A: Not employed any day of month 2B: Employee not a full-time employee 2C: Enrolled

1E 1E 1E 1E 1E 1E 1E 1H 1H 1H 1H 1H

148

2C 2C 2C 2C 2C 2C 2C 2B 2A 2A 2A 2A

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Question: Reporting COBRA Coverage

Question: How should an employer report enrollment information for self-insured coverage provided to a non-employee COBRA beneficiary (for example, the former spouse of an employee), member of the board of directors, or retired employee?

Answer: For these individuals, a self-insured employer should enter code 1G, Offer of coverage to employee who was not a full-time employee for any month of the calendar year, on line 14 of Part II of Form 1095-C and completing Part III of Form 1095-C. Remember that Form 1095-C requires the recipient’s SSN on line 2 in all instances, so Form 1095-C cannot be used for covered individuals who have not provided a SSN to the employer. For example: a non-employee director

a terminated employee receiving COBRA coverage who terminated employment in a previous calendar year

a retired employee who terminated employment in a previous calendar year, or

a family member who is receiving COBRA coverage independent of the individual Use Form 1095-B as an alternative to Form 1095-C for an individual who was not an employee on any day

of the calendar year

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Question: Reporting COBRA coverage for fully insured plan

Question: How do I report the remaining months after an employee terminates from employment where there is a COBRA offer? For example, employee is covered as active employee, but then is terminated on May 15, 2015. Answer: COBRA elected:

Line 14: Jan thru Dec = 1E (offer of coverage)

Line 15: Jan thru April = Lowest-cost self-only premium; May thru Dec = Self-only COBRA premium

Line 16: Jan thru Dec = 2C (enrolled in coverage)

Then in following year (2016), no obligation to report

COBRA not elected:

Line 14: Jan thru April = 1E; May = 1H; June thru Dec = 1H

Line 15: Jan thru April = Enter Cost; May thru Dec = No entry

Line 16: Jan thru April = 2C; May = 2B; June thru Dec = 2A

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Form 1095-C: Part III, Self-insured Plans Part III: Lines 17 to 22

Only required if plan is self-insured

Must list all enrolled persons (FTE and part-time; spouses, dependents) if enrolled any day during the month

Include social security number

Can use date of birth instead of social security number after good faith

efforts are exhausted (three tries)

First effort should be made at time of enrollment

Second effort should be made before December 31 of the year in which open enrollment occurred

Third effort should be made before December 31 of the year the person is enrolled

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Form 1095-C: Part III, Self-insured Plans

600316 Form 1095-C (2015) Page 3 Name of employee Social security number (SSN)

Part III Covered Individuals — Continuation Sheet

(a) Name of covered individual(s) (b) SSN (c) DOB (If SSN is not available)

(d) Covered all 12 months

(e) Months of coverage

23 DR FT AS OF 24 August 6, 2015 26 DO NOT FILE 27

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34 Form 1095-C (2015

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Section 6056 Reporting: Practical Considerations

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Reporting: Information to Gather/Track in 2015

Name, address and SS/TIN for each FTE

Employees’ hours worked

Measurement period calculations

Offers of coverage (including waivers)

Months during which FTE was actually covered

Employee contribution amounts: Cost of coverage

Monthly basis

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Practical Considerations: Internal Internal groups to coordinate

HR

Benefits Administration

Payroll

Finance

Executives (if risking penalties)

Managers and Supervisors

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Practical Considerations: External External groups to coordinate

Payroll vendors

Benefit administration vendors

TPAs (if involved in plan administration, such as coverage offers and terminations, etc.)

Attorney

Tracking/reporting vendors

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Practical Considerations: Reporting Vendors

Vendors are available to assist!!

Tracking employee hours

Reporting (both 6055 and 6056)

Separately or together

NFP-preferred Vendors

Syncstream

Bswift

Next Generation

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Should I go with a vendor? Factors to consider:

Size of employer/number of employees

Internal capacity

Type of industry and workforce

Payroll/Benefit Administration vendor platforms

Ability to provide vendor with appropriate information

Control over EE work schedules/hours

Cost of vendor services

Time of year

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Miniature Case Studies: Vendor Use Needed Employer A: Vendor assistance

Smaller employer

Non-stable workforce

Few internal resources

Employer B: Vendor assistance

Larger employer (1000+)

Large variable hour/seasonal workforce

Already on vendor’s payroll system (bswift)

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Miniature Case Studies: Vendor Use Not Needed

Employer C: No vendor assistance

Mid-range employer (350-400)

Strong HR/Ben Admin team

Lots of control over EE schedule/hours

Employer D: No vendor assistance

Larger employer (1000+)

Big HR/Ben Admin team

Workforce fairly stable

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Next steps

Identify full time employees

Independent Contractors

Temporary staffing employees

Implement measurement periods for variable hour, seasonal, and part-time employees

Determine affordability strategy

Keep thorough records

Employees’ hours of service

Offer of coverage

Enrollments

Familiarize yourself with reporting forms and codes

Consider vendor solutions

Stay tuned for more guidance

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QUESTIONS?

Employer Reporting under the ACA - efgmbenefits.com Reporting... · Section 6055 Reporting...

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