Affordable Care ActTracking and Reporting

Getting Ready for 2016July 16, 2015

Additions to theInternal Revenue Code

Section 6055 —Individual Mandate

Section 6056 —Employer Mandate

Confirms if individuals have satisfied the

“Individual Mandate.” This section applies to the entity that insures the

coverage.

Determines whether large employers have satisfied

the “Pay or Play” rule. This section applies to

Applicable Large Employers.

IRS Sections 6055 and 6056are about Reporting

To Individuals To The IRS

Via Form 1095-Band/or Form 1095-C

Via Form 1094-B and/or1094-C

pluscopies of the forms

provided to individuals

Non-Calendar Year Plans

• The reporting requirements and filing deadlines do not changefor non-calendar year plans.

• Data for all of 2015 must be captured and reported.

• Section 4980H Transition Relief options

Penalties for Non-Compliance• By 2019, the government expects to collect $25 billion

in penalties from businesses for failures to comply with the ACA

• Penalties for non-compliance are $250 per return, up to $3 million

• Employers who can show a good-faith effort to comply will not be penalized in 2016

Do you have 50 or more Full-time Equivalent employees?

Understanding Employer Obligations

No. Are any of your medical plans

self-insured?

Yes. As an Applicable Large Employer (ALE), you are subject to Section 6056. Are you self-insured?

Yes.You are subject to Section 6055

and will use Forms 1094-B and 1095-B.

No.You are not

subject to the new reporting requirements.

Yes.Self-insured

employers will use Forms 1094-C and 1095-C, Parts

1, 2 and 3.

No. Fully-insured

employers will use Forms 1094-C and

1095-C, Parts 1 and 2 (not Part 3).

Small Employer, Self-Funded Do you have 50 or more Full-time Equivalent employees?

No. Are any of your medical plans

self-insured?

Yes.You are subject to Section 6055

and will use Forms 1094-B and 1095-B.

No.You are not

subject to the new reporting requirements.

Yes.Self-insured

employers will use Forms 1094-C and 1095-C, Parts

1, 2 and 3.

Yes. As an Applicable Large Employer (ALE), you are subject to Section 6056. Are you self-insured?

No. Fully-insured

employers will use Forms 1094-C and

1095-C, Parts 1 and 2 (not Part 3).

What Forms Go Where?For the Self Funded Organization:

IRS

1095 – BProvided by

Employer, for every employee. Sent via

mail – 2/29/16Sent electronically –

3/31/16

1094 – BProvided by the

Employer. Sent via mail – 2/29/16

Sent electronically –3/31/16

Employee

1095 – B Provided by the

Employer. Sent by 1/31/16

1095 – B Line 8 Codes

A. Small Business Health Options Program (SHOP). B. Employer-sponsored coverage. C. Government-sponsored program. D. Individual market insurance. E. Multiemployer plan. F. Miscellaneous minimum essential coverage.

Where is the DataPayroll W-2 and affordability safe harbor

calculation

Time Keeping Service hours for determination of full-time status

Benefits Administration Eligibility, benefit status, dependent information, coverage offer dates, waivers, employees on leave

Questions to AskFact Finding? • What are you doing to help me

with ACA Reporting?• How much does it cost• ARE WE PART OF A CONTROL

GROUPIntegration? • How much time does it take to

implement into our system• Does it integrate into time

keeping, payroll, ben admin?

What does the client need to do?

• Discuss budgets and strategy• Make a decision TODAY

CONTROL GROUPScenario • Vicki’s “I Don’t Know Café” has 30 Full

Time EEs that work 35 hours per week• Vicki’s second business operation “You

Choose Saloon” has 40 Part Time EEs that work 20 hours per week

Work out the Math • 30 – Full Time Employees + 26.6 FTEs (Full Time Equivalents) = 56.6 FTEs • 40 EEs * 20 hr/week / 30 hours (full

time EE hour calculation) = 26.6

FTEs Calculation: • Vicki is an Applicable Large Employer (ALE) and could potentially receive a penalty

• Will help populate and submit reports

• Implementation can take 3 - 4weeks

• Capable of integrating with payroll vendors

• Quote based on size of organization, and how many control groups

• Reasonable costs – comparative of hard vs soft $$

Next StepsJuly/August • Determine what information your payroll vendor

can provide• Engage SyncStream, if needed

September • Pull sample reports from relevant vendors

December • Run reports to collect data from January through November

January • Incorporate December data• Transfer data to IRS forms• Communicate to employees what reporting they

will receive and its purpose

• Utilize Ben Admin/Payroll Reporting function to complete form

February 1 • Distribute Form 1095-B or 1095-C to employees

February 29 or March 31(if filed electronically)

• All 2015 submissions due to IRS

Amanda Ericson, SPHR, SHRM-SCPDirector of HR Compliance Tel: (970) 584-1719 | Mobile: (970) 372-7885aericson@shirazibenefits.com

Shirazi Benefits8205 W. 20th St. | Greeley, CO 80634http://www.shirazibenefits.com

Supplemental material supplemented from: Presidio Benefits