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MANDATORY 1094C/1095C REPORTING REQUIREMENTS FOR APPLICABLE LARGE
EMPLOYERS UNDER THE AFFORDABLE CARE ACT
The Affordable Care Act, or ACA, was signed into law on March 23rd, 2010. The ACA is the federal legislation that includes Employer Shared Responsibility (ESR) provisions. The ACA added two employer reporting requirements to the Internal Revenue Code taking effect in 2015:
• Code § 6055 requires employers that provide minimum essential coverage (MEC) under a self-funded plan to provide an annual statement to covered employees and former employees (including information about covered dependents).
• Code § 6056 requires applicable large employers (ALEs) to provide an annual statement to each full-time employee detailing the employer’s health coverage offer (or lack of offer).
History And Terminology
Agenda
2. Employer Shared Responsibility: 2015/2016 Overview 2. Employer Shared Responsibility: 2015/2016 Overview
1. The “ALE” And Control Groups 1. The “ALE” And Control Groups
3. 1094-C / 1095-C: What Information Is Reported3. 1094-C / 1095-C: What Information Is Reported
4. Self-Funded Plans4. Self-Funded Plans
5. TelePayroll’s Role In Your Compliance5. TelePayroll’s Role In Your Compliance
6. What’s Next and Q&A Session6. What’s Next and Q&A Session
ALE Members
An employer with 50 or more Full-Time Equivalent (FTE)employees is an Applicable Large Employer (ALE) under the ACA. Transitional relief has been given to
ALE’s with 50 – 99 FTE’s.
An employer with 50 or more Full-Time Equivalent (FTE)employees is an Applicable Large Employer (ALE) under the ACA. Transitional relief has been given to
ALE’s with 50 – 99 FTE’s.
An ALE member may be a part of such a group, but a single employer—not affiliated with other employers — is also identified in the rule as an ALE member, even though
it is only a member of itself.
An ALE member may be a part of such a group, but a single employer—not affiliated with other employers — is also identified in the rule as an ALE member, even though
it is only a member of itself.
New Filing Requirements For ALE’S
The ACA treats aggregated employer groups such as parents or subsidiaries, or control groups, as single employers for
purposes of determining large-employer status under the ESR requirement. Each employer within the control group is
identified as an “ALE Member”.
The ACA treats aggregated employer groups such as parents or subsidiaries, or control groups, as single employers for
purposes of determining large-employer status under the ESR requirement. Each employer within the control group is
identified as an “ALE Member”.
ESR 2015 / 2016 Overview
Number Of Employees And
Applicable Dates
Number Of Employees And
Applicable Dates
20152015
2016 AndBeyond
2016 AndBeyond
Less Than 25 FTE Employees - May be eligible for the Small Business Tax Credit
50 - 99 FTE Employees - Subject to ESR – 1/1/16
100 Or More FTE Employees - Subject to ESR – 1/1/15
250 Or More Employee W-2’s - Report cost of health care coverage on W2’s
Less Than 25 FTE Employees - May be eligible for the Small Business Tax Credit
50 - 99 FTE Employees - Subject to ESR – 1/1/16
100 Or More FTE Employees - Subject to ESR – 1/1/15
250 Or More Employee W-2’s - Report cost of health care coverage on W2’s
ALE’s are required to report specific information to the Internal Revenue Service on Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. The reporting period began 1/1/15 and the returns are filed annually beginning 1/31/16 for calendar year 2015.
ALE’s are required to report specific information to the Internal Revenue Service on Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. The reporting period began 1/1/15 and the returns are filed annually beginning 1/31/16 for calendar year 2015.
Transitional safe-harbor relief ends for ALE’s with 50-99 FTE employees. This group is required to report and file forms 1094-C and 1095-C in accordance with IRS code sections 6055 and 6056.
Transitional safe-harbor relief ends for ALE’s with 50-99 FTE employees. This group is required to report and file forms 1094-C and 1095-C in accordance with IRS code sections 6055 and 6056.
What Information Gets Reported?
Form 1094-C And 1095-C
Form 1095-C, Employer Provided Health Insurance Offer And Coverage• For each month in 2015, Identify which employees are full-time employees:
1) Determine whether you offered health coverage to that employee (and dependents) for that month; and2) Determine the type of health coverage offered
• Minimum essential coverage• Minimum value coverage that is affordable
Form 1095-C, Employer Provided Health Insurance Offer And Coverage• For each month in 2015, Identify which employees are full-time employees:
1) Determine whether you offered health coverage to that employee (and dependents) for that month; and2) Determine the type of health coverage offered
• Minimum essential coverage• Minimum value coverage that is affordable
Form 1094-C, Transmittal Of Employer Provided Health Insurance Offer And Coverage Information Returns
1) Information about whether you offered coverage to 70 percent of your full-time employees (and dependents)2) Total number of Forms 1095-C you issued to employees3) Full-time employee counts by month4) Total employee counts by month5) Information about members of your aggregated ALE group, if any
Form 1094-C, Transmittal Of Employer Provided Health Insurance Offer And Coverage Information Returns
1) Information about whether you offered coverage to 70 percent of your full-time employees (and dependents)2) Total number of Forms 1095-C you issued to employees3) Full-time employee counts by month4) Total employee counts by month5) Information about members of your aggregated ALE group, if any
There Are Differences For Self-Funded Plans
Self-Funded Plans
If the employer self-funds its plan(s), the employer also will use Forms 1094-C and 1095-C to report information to employees and the IRS. There are differences in the requirements for employers with self-funded plans under the ACA, including requirements that apply regardless of whether the employer is an ALE or not.
If the employer self-funds its plan(s), the employer also will use Forms 1094-C and 1095-C to report information to employees and the IRS. There are differences in the requirements for employers with self-funded plans under the ACA, including requirements that apply regardless of whether the employer is an ALE or not.
Final Draft Forms 1094C And 1095C
Employers of any size that provide minimum essential coverage (MEC) under a self-funded plan are to provide an annual statement to covered employees and former employees, including information about covered dependents.
If you self-fund any plan providing minimum essential coverage in 2015, regardless of whether you are an ALE, identify all covered persons (e.g., full-time employees, part-time employees, dependents).
Employers of any size that provide minimum essential coverage (MEC) under a self-funded plan are to provide an annual statement to covered employees and former employees, including information about covered dependents.
If you self-fund any plan providing minimum essential coverage in 2015, regardless of whether you are an ALE, identify all covered persons (e.g., full-time employees, part-time employees, dependents).
The Forms
HOW CAN WE HELP YOU?
Helping Our Clients Comply
Clients with TelePayroll’s ACA Monitoring Service
1094C/1095C filing is included in this service
free of charge. TelePayroll may need to
collect additional insurance information to
complete filing.
Clients without ACA Monitoring or TelePay Insurance
1094C/1095C filing available for a nominal
fee. TelePayroll will need to collect benefit,
insurance and employee information to complete
filing.
TelePayroll is prepared to file our clients’ Forms 1094-Cand 1095-C. ALE clients that are required to file these
returns belong to one of three groups
TelePayroll is prepared to file our clients’ Forms 1094-Cand 1095-C. ALE clients that are required to file these
returns belong to one of three groups
Clients with health insurance through TelePay Insurance
ACA Monitoring and 1094C/1095C filing is
included in this service free of charge.
TelePayroll has all necessary information
to complete filing.
1094-C / 1095-C Checklist
2. ACA Monitoring Clients You will be contacted separately for additional
information
1. TelePayroll Insurance Clients Done, Included
3. Non-Monitoring/Non-Insurance Clients Complete the “Opt-In” form
Provide the additional info requested on the opt-in form
What’s Next?
What’s Next
Thank you for attending this presentation!All participants will receive a follow up email with the following:
1. A copy of this presentation2. An “opt-in” form and a list of information needed from
your company3. Information about TelePayroll ACA Monitoring Services4. Information from TelePay Insurance
ACA Monitoring Services
Dorri Komarek(800) 442-4988 ext. [email protected]
TelePay Insurance
Michael Gilberstadt(800) 442-4988 ext. 101
General Compliance
Carri Lemmon(800) 442-4988 ext. [email protected]