際際滷

際際滷Share a Scribd company logo

SterlingRisk & ECI Present: Compliance With the ACA 6055 & 6056 Reporting

Download as PPTX, PDF
N
ntoscano50

June 25, 2015 Hosted by SterlingRisk and Presented by Jennifer Reed from ECI During the presentation, Jennifer Reed from ECI will cover the logistics of these requirements. This presentation is unique, because Jennifer has a core benefits and HR Technology consulting background, and as a result she will be focusing on the logistics of the ACA reporting. Some of you may have seen a webinar or seminar that covers the law, but not many have had the chance to hear someone speak about the details regarding how the reporting will actually happen. Jennifer also has experience presenting nationally on this topic.

1 of 32
Download to read offline
ACA 6055 & 6056 Reporting Jennifer Reed Manager of Strategic Partnerships and Alliances o. 903-771-4502 | m. 574-333-7207 jreed@ecipay.com
Agenda Introductions ACA 6055/6056 Reporting requirements (From a HR technology perspective) Employer Options
Jennifer Reed 8 Years Strictly in Core Employee Benefits (CIGNA Healthcare) 1 Year sales for a Benefits Enrollment Company Instant Benefits (PlanSource) 5 Years of HR Technology Consulting (HRT Advisors) Worked with 50+ Brokers from FL to CA Consulted with approximately 600 Employers Ranging in size from Small - 16,000+ Employees Intimate working relationship with vendors such as ADP, Ceridian, Ultimate Software, Paylocity, Ascentis, Paycom, ECI, 4MyBenefits (IPA), bswift, BusinesSolver, SmartBen, BenefitFocus, and many others Manager of Strategic Partnerships & Alliances for ECI 3rd Party relationships such as HR Consultants, Brokers, and HR Tech Consultants.
Mid Market Focus 100 to 5,000+ Employee Organizations Presence Corporate in Elkhart, IN 600 Clients Nationally HCM Recruitment (Optional) HRIS Payroll Benefits Enrollment (Optional) Learning Management (Optional) Performance Management (Optional) 3 Levels Reporting and 450+ Standard Reports Time & Attendance (Optional) Customer for Life Program 98% Client Retention Rate 92% Agree to be ECI References! PAEPM Pricing Model (Per Active Employee Per Month) Who is ECI? Who is ECI?
ACA 6055/6056 Reporting Requirements & Employer Options
Government is reliant on Employer Reporting to track compliance (trigger the penalties). (Commonly referred to as ACA Reporting, End of the year reporting, 6055/6066 Reporting, 4980h, or 1094/1095 B and C forms) Individuals are currently enrolled in public exchanges and receiving tax subsidies Individuals are required by law to have Minimal Essential Coverage or pay a tax Penalty Employers are required by Law to offer Affordable MEC (Minimal Essential Coverage) and Minimal Value (MV) or pay a penalty. Important: Without this reporting, there is no way for the government to determine if the individuals are actually eligible for the subsidies, if they are indeed enrolled in insurance, or if an employer penalty applies. Why Do I need to Do This?
First mandatory reporting in January/February 2016 for 2015 Calendar Year Applies to ALL ALEs (Applicable Large Employers) Applicable Large Employer Definition: Employers with 50 or more full-time employees (including full-time equivalent employees) Employers with 50-99 may qualify for Transition Relief (see your broker regarding qualifications) in 2015 from the No Coverage/Unaffordable Penalty, but are still REQUIRED to report in 2016 for 2015 Tax Year. ALE status is determined on a Controlled Group Basis meaning generally if you have multiple EINs with common ownership and the overall group is 50+ employees then you are considered an ALE. **Talk to ERISA counsel if analysis is needed in this area Why Do I Need to be Ready Now?
Also Applies to Self-Insured employers with < 50 Employees Requires Employer Month to Month Tracking of: Total Number of Full Time Employees Total Number of Employees Offer of Coverage (not Enrollment) For any Employee that was full time any one month during 2015 Employee Only Rate of lowest Offered (Not necessarily Enrolled) MV Coverage Enrollment of Employee and their dependents (Self Insured Only) Any Non Employee Enrollment on your plan (Self Insured Only) Why Do I Need to be Ready Now?
ACA Acronym Cheat Sheet ACA= Affordable Care Act PPACA= Patient Protection and Affordable Care Act (Used interchangeably with ACA) ALE = Applicable Large Employer MEC = Minimum Essential Coverage MV = Minimum Value
Definition of MEC Definition of MEC (Minimum Essential Coverage) Generally means if you offer Employer sponsored coverage it is considered Minimum Essential Coverage.
Definition of MV Definition of MV (Minimum Value) MV is the 60% Actuarial Value and is met when a plan pays on average at least 60% of the actuarial value of allowed benefits under the plan.
Form Cheat Sheet Aggregate Level Form (like a W-3 but ACA related Information) Individual Employee Statement (Mailed to the EE like a W-2 and information specific to that employee Like a W-2) Self Insured Less than 50 Employees (Optional to report Non Employees for an ALE) For All ALEs (Self Insured and Fully Insured 50+ EEs) ** Note Every individual who has health insurance regardless of the source (Employer, private, or public exchange will receive a form (A, B, or C). Above is primary focused on Employer Reporting only.) 109... 109... 1094/5.. 1094/5..
1094 C (IRS Transmittal)
1094 C (IRS Transmittal)
1094 C (IRS Transmittal)
1095 C (Employee Statement) Benefits Enrollment Payroll
1095 C (Employee Statement)
1095 C (Employee Statement)
The employer is required to file Forms 1094-C and 1095-C with the IRS and to furnish a copy of Form 1095-C to the employee. You must file Forms 1094-C and 1095-C by February 28 (29th for 2015 tax year) if filing on paper (or March 31 if filing electronically) of the year following the calendar year to which the return relates.. Form 1095-C must be furnished to the individual by January 31 of the year following the year to which the return relates (First ones due Feb 1st). Same as W2s. 1094/5 C (Some Important Notes)
Filers of 250 or more information returns must file the returns electronically. The Internal Revenue Service released Draft Publication 5165 in April 2015 (http://www.irs.gov/PUP/for_taxpros/software_developers/in formation_returns/Draft_Pub_5165_04_2015.pdf) to assist with developing software for the AIR system. 1094/5 C (Some Important Notes)
1094/5 C (Some Important Notes) ACA Information Returns (AIR) Working Group Meeting: Overview of Draft Publication 5164 (May 28, 2015) (PDF)
ACA Reporting Options?!
Before you look for a Solution Figure out what data you are tracking now and where it is stored Figure out what additional data you need to be tracking (E.g. Offer of Enrollment) Figure out if you are REQUIRED to file electronically Decide if you want to handle this internally or look for a vendor to provide this service
Before you look for a Solution 1) In House (Look for tools Potentially to help you) Do I have IT involved if I am required to file electronically? What systems do I have in place or Need? What all can my internal solution provide and what data can it store? Where am I tracking my benefit data today? Do I need to start tracking enrollment or when I offer coverage? 2) Outsource Do I currently Outsource my Payroll? Does my current payroll vendor provide this? Where am I tracking my benefit data today? Do I need to add on any additional functionality? Is the vendor I am considering for this collecting it in a way that will protect me if I am audited?
In House - Options Internal Payroll System Replace with an HRIS/Payroll System? Compliment with an Online Enrollment Tool or ACA Tool? Track Everything Manually?
In House Points to Consider Systems that employers utilize to process payroll in house are typically not strong in the benefits enrollment area (Accounting systems, ERP, Sage Abra, and etc). Many may prefer to utilize a separate Benefits Enrollment solution for Cost reasons (ADP Enterprise, SAP, and etc). Many are tracking Benefits data manually in excel or paper files if they are tracking it at all Employers in this category may rely on the carrier to keep track of their benefits enrollment information 6055/6 reporting can be more cumbersome from a time perspective on HR department than traditional payroll processing.
Outsource- Options Current Payroll Outsourced Review adding on functionality with your current provider? Replace your provider with a stronger HRISpayroll provider? Compliment with an Online Enrollment Tool or ACA Tool?
Outsource Points to Consider Not All Payroll Companies are created Equal! All reputable Payroll companies should offer this service; however, depending if the vendor has benefits enrollment may determine cost or how accurate the reporting is. (E.g. Small Local payroll company may sell payroll only and not offer benefits enrollment; therefore, they may not track whether a coverage was offered or enrolled) Payroll companies already submit electronic transmittals to the IRS, so they do not need to wait on approval. If Benefits Enrollment is done in a 3rd party system or manually, then a custom interface or manual entry may be required in order to gather all the data needed for reporting. Ask detailed questions and never make assumptions and involve your broker in this discussion when possible. Your broker may not know technology, but they know ACA and can ask the hard questions you may have not thought of.
Benefits Enrollment Vendors (Benetrac, bSwift, Benefit Focus, and etc) Most Reputable Benefits Enrollment Companies Track all the data needed for the reporting with the Exception of some the data on the 1094C (Authoritative EINs/Total Employee Count). Some Benefit Enrollment Companies offer an ACA tool set that is a 3rd party rebranded stand-alone ACA vendor (E.g. Equifax). Potential Problem Most Benefit Enrollment Companies do not want the liability of filing electronically to the IRS, and nor have they filed to the IRS in the past for their customers. Potential Problem - Benefit Enrollment companies can easily pre populate the PDF forms, but this leaves the employer to responsible to manually file to the IRS.
Stand Alone ACA Vendors (Equifax, Health FX, and others) Most offer Front End reporting (Affordability, Measurement Period, and etc) and dashboards. Best of Breed type modeling capabilities Some state they will be filing electronically on behalf of their customers, but are waiting for approval from the IRS. Potential Problem - All the data still needs to be brought in from PayrollTime & attendance. Potential Problem - Pricing tends to push these products into the larger market (2000+ EEs)
Reporting Failures Penalty is up to $100 per statement/return Maximum annual penalty of $1.5 million Limited relief applies for the 2015 return due in 2016 if incomplete or incorrect information is reported Must meet deadlines Must show good faith compliance
Questions and thank you! Jennifer Reed Manager of Strategic Partnerships and Alliances o. 903-771-4502 | m. 574-333-7207 jreed@ecipay.com

More Related Content

SterlingRisk & ECI Present: Compliance With the ACA 6055 & 6056 Reporting

  • 1. ACA 6055 & 6056 Reporting Jennifer Reed Manager of Strategic Partnerships and Alliances o. 903-771-4502 | m. 574-333-7207 jreed@ecipay.com
  • 2. Agenda Introductions ACA 6055/6056 Reporting requirements (From a HR technology perspective) Employer Options
  • 3. Jennifer Reed 8 Years Strictly in Core Employee Benefits (CIGNA Healthcare) 1 Year sales for a Benefits Enrollment Company Instant Benefits (PlanSource) 5 Years of HR Technology Consulting (HRT Advisors) Worked with 50+ Brokers from FL to CA Consulted with approximately 600 Employers Ranging in size from Small - 16,000+ Employees Intimate working relationship with vendors such as ADP, Ceridian, Ultimate Software, Paylocity, Ascentis, Paycom, ECI, 4MyBenefits (IPA), bswift, BusinesSolver, SmartBen, BenefitFocus, and many others Manager of Strategic Partnerships & Alliances for ECI 3rd Party relationships such as HR Consultants, Brokers, and HR Tech Consultants.
  • 4. Mid Market Focus 100 to 5,000+ Employee Organizations Presence Corporate in Elkhart, IN 600 Clients Nationally HCM Recruitment (Optional) HRIS Payroll Benefits Enrollment (Optional) Learning Management (Optional) Performance Management (Optional) 3 Levels Reporting and 450+ Standard Reports Time & Attendance (Optional) Customer for Life Program 98% Client Retention Rate 92% Agree to be ECI References! PAEPM Pricing Model (Per Active Employee Per Month) Who is ECI? Who is ECI?
  • 6. Government is reliant on Employer Reporting to track compliance (trigger the penalties). (Commonly referred to as ACA Reporting, End of the year reporting, 6055/6066 Reporting, 4980h, or 1094/1095 B and C forms) Individuals are currently enrolled in public exchanges and receiving tax subsidies Individuals are required by law to have Minimal Essential Coverage or pay a tax Penalty Employers are required by Law to offer Affordable MEC (Minimal Essential Coverage) and Minimal Value (MV) or pay a penalty. Important: Without this reporting, there is no way for the government to determine if the individuals are actually eligible for the subsidies, if they are indeed enrolled in insurance, or if an employer penalty applies. Why Do I need to Do This?
  • 7. First mandatory reporting in January/February 2016 for 2015 Calendar Year Applies to ALL ALEs (Applicable Large Employers) Applicable Large Employer Definition: Employers with 50 or more full-time employees (including full-time equivalent employees) Employers with 50-99 may qualify for Transition Relief (see your broker regarding qualifications) in 2015 from the No Coverage/Unaffordable Penalty, but are still REQUIRED to report in 2016 for 2015 Tax Year. ALE status is determined on a Controlled Group Basis meaning generally if you have multiple EINs with common ownership and the overall group is 50+ employees then you are considered an ALE. **Talk to ERISA counsel if analysis is needed in this area Why Do I Need to be Ready Now?
  • 8. Also Applies to Self-Insured employers with < 50 Employees Requires Employer Month to Month Tracking of: Total Number of Full Time Employees Total Number of Employees Offer of Coverage (not Enrollment) For any Employee that was full time any one month during 2015 Employee Only Rate of lowest Offered (Not necessarily Enrolled) MV Coverage Enrollment of Employee and their dependents (Self Insured Only) Any Non Employee Enrollment on your plan (Self Insured Only) Why Do I Need to be Ready Now?
  • 9. ACA Acronym Cheat Sheet ACA= Affordable Care Act PPACA= Patient Protection and Affordable Care Act (Used interchangeably with ACA) ALE = Applicable Large Employer MEC = Minimum Essential Coverage MV = Minimum Value
  • 10. Definition of MEC Definition of MEC (Minimum Essential Coverage) Generally means if you offer Employer sponsored coverage it is considered Minimum Essential Coverage.
  • 11. Definition of MV Definition of MV (Minimum Value) MV is the 60% Actuarial Value and is met when a plan pays on average at least 60% of the actuarial value of allowed benefits under the plan.
  • 12. Form Cheat Sheet Aggregate Level Form (like a W-3 but ACA related Information) Individual Employee Statement (Mailed to the EE like a W-2 and information specific to that employee Like a W-2) Self Insured Less than 50 Employees (Optional to report Non Employees for an ALE) For All ALEs (Self Insured and Fully Insured 50+ EEs) ** Note Every individual who has health insurance regardless of the source (Employer, private, or public exchange will receive a form (A, B, or C). Above is primary focused on Employer Reporting only.) 109... 109... 1094/5.. 1094/5..
  • 13. 1094 C (IRS Transmittal)
  • 14. 1094 C (IRS Transmittal)
  • 15. 1094 C (IRS Transmittal)
  • 16. 1095 C (Employee Statement) Benefits Enrollment Payroll
  • 17. 1095 C (Employee Statement)
  • 18. 1095 C (Employee Statement)
  • 19. The employer is required to file Forms 1094-C and 1095-C with the IRS and to furnish a copy of Form 1095-C to the employee. You must file Forms 1094-C and 1095-C by February 28 (29th for 2015 tax year) if filing on paper (or March 31 if filing electronically) of the year following the calendar year to which the return relates.. Form 1095-C must be furnished to the individual by January 31 of the year following the year to which the return relates (First ones due Feb 1st). Same as W2s. 1094/5 C (Some Important Notes)
  • 20. Filers of 250 or more information returns must file the returns electronically. The Internal Revenue Service released Draft Publication 5165 in April 2015 (http://www.irs.gov/PUP/for_taxpros/software_developers/in formation_returns/Draft_Pub_5165_04_2015.pdf) to assist with developing software for the AIR system. 1094/5 C (Some Important Notes)
  • 21. 1094/5 C (Some Important Notes) ACA Information Returns (AIR) Working Group Meeting: Overview of Draft Publication 5164 (May 28, 2015) (PDF)
  • 23. Before you look for a Solution Figure out what data you are tracking now and where it is stored Figure out what additional data you need to be tracking (E.g. Offer of Enrollment) Figure out if you are REQUIRED to file electronically Decide if you want to handle this internally or look for a vendor to provide this service
  • 24. Before you look for a Solution 1) In House (Look for tools Potentially to help you) Do I have IT involved if I am required to file electronically? What systems do I have in place or Need? What all can my internal solution provide and what data can it store? Where am I tracking my benefit data today? Do I need to start tracking enrollment or when I offer coverage? 2) Outsource Do I currently Outsource my Payroll? Does my current payroll vendor provide this? Where am I tracking my benefit data today? Do I need to add on any additional functionality? Is the vendor I am considering for this collecting it in a way that will protect me if I am audited?
  • 25. In House - Options Internal Payroll System Replace with an HRIS/Payroll System? Compliment with an Online Enrollment Tool or ACA Tool? Track Everything Manually?
  • 26. In House Points to Consider Systems that employers utilize to process payroll in house are typically not strong in the benefits enrollment area (Accounting systems, ERP, Sage Abra, and etc). Many may prefer to utilize a separate Benefits Enrollment solution for Cost reasons (ADP Enterprise, SAP, and etc). Many are tracking Benefits data manually in excel or paper files if they are tracking it at all Employers in this category may rely on the carrier to keep track of their benefits enrollment information 6055/6 reporting can be more cumbersome from a time perspective on HR department than traditional payroll processing.
  • 27. Outsource- Options Current Payroll Outsourced Review adding on functionality with your current provider? Replace your provider with a stronger HRISpayroll provider? Compliment with an Online Enrollment Tool or ACA Tool?
  • 28. Outsource Points to Consider Not All Payroll Companies are created Equal! All reputable Payroll companies should offer this service; however, depending if the vendor has benefits enrollment may determine cost or how accurate the reporting is. (E.g. Small Local payroll company may sell payroll only and not offer benefits enrollment; therefore, they may not track whether a coverage was offered or enrolled) Payroll companies already submit electronic transmittals to the IRS, so they do not need to wait on approval. If Benefits Enrollment is done in a 3rd party system or manually, then a custom interface or manual entry may be required in order to gather all the data needed for reporting. Ask detailed questions and never make assumptions and involve your broker in this discussion when possible. Your broker may not know technology, but they know ACA and can ask the hard questions you may have not thought of.
  • 29. Benefits Enrollment Vendors (Benetrac, bSwift, Benefit Focus, and etc) Most Reputable Benefits Enrollment Companies Track all the data needed for the reporting with the Exception of some the data on the 1094C (Authoritative EINs/Total Employee Count). Some Benefit Enrollment Companies offer an ACA tool set that is a 3rd party rebranded stand-alone ACA vendor (E.g. Equifax). Potential Problem Most Benefit Enrollment Companies do not want the liability of filing electronically to the IRS, and nor have they filed to the IRS in the past for their customers. Potential Problem - Benefit Enrollment companies can easily pre populate the PDF forms, but this leaves the employer to responsible to manually file to the IRS.
  • 30. Stand Alone ACA Vendors (Equifax, Health FX, and others) Most offer Front End reporting (Affordability, Measurement Period, and etc) and dashboards. Best of Breed type modeling capabilities Some state they will be filing electronically on behalf of their customers, but are waiting for approval from the IRS. Potential Problem - All the data still needs to be brought in from PayrollTime & attendance. Potential Problem - Pricing tends to push these products into the larger market (2000+ EEs)
  • 31. Reporting Failures Penalty is up to $100 per statement/return Maximum annual penalty of $1.5 million Limited relief applies for the 2015 return due in 2016 if incomplete or incorrect information is reported Must meet deadlines Must show good faith compliance
  • 32. Questions and thank you! Jennifer Reed Manager of Strategic Partnerships and Alliances o. 903-771-4502 | m. 574-333-7207 jreed@ecipay.com