Will We See You in Vegas?

Barry-150x150KTP Advisors, a specialty advisory firm in the areas of retiree health benefits, private exchange comparisons, and ACA reporting, will be attending the IHC Forum West in Las Vegas, Nevada in November. As part of the event, Barry Eyre, KTP’s VP of Business Development, will be participating in multiple sessions to share his insights, alongside other industry experts, on the private exchange marketplace.

His first session: Session 107 – “Defined Contribution & Private Exchange” will feature guest speaker, Jeff Yaniga, Chief Revenue Officer at Maestro Health. Their discussion will look at the cold, hard facts of private exchanges. Presenting a curated selection of statistics and insights, Yaniga will fact check information presented by benefits pundits and provide thought provoking ideas on how to optimize the way we all do business. Be sure to catch this great discussion on Tuesday, November 17th from 10:30 a.m. – 11:30 a.m.

As a panel moderator for Session 207, Barry will be leading the discussion on the latest private exchange trends and strategies for retirees. The panel will feature exchange providers, as well as employers who have implemented a private exchange option for their retirees. Attendees will leave this session with an appreciation for:

  • Private exchange options available for employers who offer, or are obligated to provide, retiree health benefits;
  • Best practices in providing retiree health benefits through a private exchange;
  • The cost savings an employer can anticipate by implementing a private exchange option to satisfy retiree health obligations.

Will we see you in Vegas? We hope to see you there! For the full agenda, please click here.

The Institute for HealthCare Consumerism’s IHC FORUM Conference Series are the only ihc-FORUM-2014-logo-no-tagnational events 100% dedicated to health care consumerism. Through cutting-edge workshops, general sessions, pre-conference events and networking opportunities, attendees leave with relevant insights from industry thought leaders and policymakers on how to navigate defined contributions and exchanges, cut costs, engage employees and comply with current healthcare laws. FORUM-goers also have an unprecedented opportunity to learn from peers who have successfully adopted healthcare consumerism programs.

New IRS Resource helps Employers Understand the Health Care Law

The_Affordable_Care_ActThe new ACA Information Center for Applicable Large Employers page on IRS.gov features information and resources for employers of all sizes on how the health care law may affect them if they fit the definition of an applicable large employer.

The web page includes the following sections:

  • What’s Trending for ALEs,
  • How to Determine if You are an ALE,
  • Resources for Applicable Large Employers, and
  • Outreach Materials.

Visitors to the new page will find links to:

  • Detailed information about tax provisions including information reporting requirements for employers,
  • Questions and answers, and
  • Forms, instructions, publications, health care tax tips, flyers and videos.

Although the vast majority of employers will not be affected, you should determine if you are an applicable large employer.  If you averaged at least 50 full-time employees, including full-time equivalent employees, during 2014, you are most likely an ALE for 2015. If you have fewer than 50 full-time employees, you may be considered an applicable large employer if you share a common ownership with other employers. As an applicable large employer, you should be taking steps now to prepare for the coming filing season.

In 2016, applicable large employers must file an annual information return – and provide a statement to each full-time employee – reporting whether they offered health insurance, and if so, what insurance they offered their employees.

If you will file 250 or more information returns for 2015, you must file the returns electronically through the ACA Information Reports system.  You should review draft Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns, now for information on the communication procedures, transmission formats, business rules and validation procedures for returns that you must transmit in 2016.

Final 2015 Health Care Reporting Forms Now Available

IRSThe Internal Revenue Service has released the final versions of two key 2015 forms and the related instructions that employers and insurers will send to the IRS and individuals this winter to report health care coverage they offered or provided.  The IRS released draft forms and instructions for 2015 this summer and the final forms and instructions for 2015 are largely unchanged from the previously released drafts.

To help employers in their preparations to meet new information reporting requirements the IRS has launched a new web page for employers.

“The IRS is working to make it as easy as possible for employers to get the information they need about the new reporting requirements. Although the vast majority of employers will not be subject to these rules because they have fewer than 50 employees, we have assembled an array of information on the IRS web site to help all employers,” said IRS Commissioner John Koskinen. “We especially encourage smaller and mid-size business to review the information to help resolve any questions they may have, including whether they are exempt from or subject to the new information reporting requirements.”

The 2015 version of Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, used by employers with 50 or more full-time employees are now available on IRS.gov. Form 1095-B,Health Coverage, primarily used by insurers and health coverage providers, including employers that sponsor self-insured plans, is also available on IRS.gov.

The health care law requires certain employers and providers to submit the 2015 forms to the IRS and individuals in early 2016. Though earlier versions of the forms were available for voluntary use in tax-year 2014, the upcoming tax season will be the first time that reporting is mandatory.

Understanding ACA Reporting Requirements

This article, Understand ACA Reporting Requirements, recently published in BenefitsPro, outlines the basics for ACA reporting. We recommend checking it out as a guideline!

Let’s explore a few of the details:

What are we talking about? The requirement mandates applicable large employers (those with 50 or more full-time equivalent employees) and small employers (under 50 full-time equivalent employees) sponsoring self-funded health plans to report on group health coverage offered to employees or to disclose that health coverage was not offered to employees in 2015.

There are two reports employers must prepare: (1) an annual information return that is filed with the Internal Revenue Service (IRS), and (2) statements to provide to full-time employees about the group health plan coverage offered. As such:

  • Internal Revenue Code § 6056 requires applicable large employers with fully-funded health insurance to provide the annual statement (IRS Form 1095-C) to each full-time employee detailing the employer’s health coverage offer.
  • Internal Revenue Code § 6055 requires employers that provide minimum essential coverage under a self-funded (uninsured) plan to provide the annual statement to covered employees (either IRS Form 1095-B or 1095-C, based on company size

When must these be filed?

  • 2015 Form 1095 (employee statement): Due February 1, 2016.
  • 2015 Form 1094 (transmittal form with copies of Forms 1095-C): Due February 29, 2016 (or March 31, 2016, if filing electronically).

What information should employers be collecting? Employers will need the following information in order to complete the reports:

  • Identifying information for the employer and employee, such as name and address.
  • Names of full-time employees for each month of the year.
  • Information about the health coverage offered by month, if any.
  • The employees’ share of the monthly premium for the lowest-cost self-only minimum value coverage.
  • Months each employee was enrolled in the coverage.
  • Months the employer met an affordability safe harbor with respect to an employee and whether other relief applied for an employee.
    If the employer offers a self-funded plan, information about the covered individuals enrolled in the plan, by month.
  • Information about whether the employer offered coverage to 70 percent of full-time employees and their dependents in 2015 (after 2015, this threshold changes to 95 percent).
  • Total number of Forms 1095-C the employer issued to employees.
  • Information about members of the aggregated applicable large employer group, if any.
  • Full-time employee counts by month.
  • Total employee counts by month.
  • Whether employers are eligible for certain transition relief

To check out the full article by BenefitsPro author, Laura Kerekes, please click here.

Understanding the ACA’s “Pay or Play Provisions”

file15Under the Affordable Care Act’s employer shared responsibility provisions (commonly referred to as the employer mandate) certain employers (called applicable large employers or ALEs) must either offer minimum essential coverage that is “affordable” and that provides “minimum value” to their full-time employees (and their dependents), or potentially make an employer shared responsibility payment to the IRS.

For this reason, the employer shared responsibility provisions are sometimes referred to as “the pay or play provisions.”

Who has to offer coverage?

Applicable large employers.  Employers with 50 or more “full-time equivalent” employees need to offer coverage or may be fined for failing to provide coverage to their full-time employees (and their dependents).   In determining whether you have 50 or more full-time equivalent employees, you must include the hours worked by your part-time employees.

For purposes of the employer shared responsibility provisions:

  • a full-time employee is, for a calendar month, an employee who works on average at least 30 hours of service per week, or 130 hours of service per month.
  • a dependent is an employee’s child (including a child who has been legally adopted or placed for adoption) who has not reached the age of 26.  Spouses are not considered dependents and neither are stepchildren or foster children.

How do you avoid the penalties?

ALEs must offer minimum essential coverage that is “affordable” and provides “minimum value” to their full-time employees. For more information on what coverage counts as minimum essential coverage, please click here.

How is this information reported?

Applicable large employers (ALE) must report to the IRS information about the health care coverage, if any, they offered to full-time employees.  ALEs also must furnish to employees a statement that includes the same information provided to the IRS.

Picture1What are the ALE reporting requirements?

Under IRS Code Section 6056, applicable large employers are required to report to the IRS whether they offer qualifying coverage to their full-time employees and their employees’ dependents. The reporting is needed by the IRS for the administration of the employer mandate requirements and to determine the assessment of penalties under IRS Code Section 4980H.

The reporting is required beginning in early 2016 to report information about 2015. There are multiple components to the reporting requirements. As an applicable large employer you will be required to complete at least two components:

  • Transmittal of Form 1094-C to the IRS
  • Distribution of Form 1095-C to Employees

If your plan design includes offering fully-insured medical plans, your insurance provider will also be completing two components:

  • Transmittal of Form 1094-B to the IRS
  • Distribution of Form 1095-B to your Employees

Note: Employers also face penalties for incorrect filing or untimely filing of these forms.