AFFORDABLE CARE ACT & TECHNOLOGY: PAST, PRESENT AND FUTURE Atlanta, GA (September 2016) Confidential and Proprietary
Meeting Agenda Introductions 2015 - Recap 2016 - Challenges for Employers Data WORKFORCE ANALYTICS Monthly Compliance Jeff S. Taylor Client Director Tax Forms Data Analytics Jeffrey.Taylor@equifax.com Subsidies 843-573-4147 Employee Communications Question and Answer Confidential and Proprietary
The Market Leader in ACA Compliance 18,200 ALE members 37,000,000 total employees managed 16,400,000 average employees per month 7,100,000 1095-Cs sent for 2015 tax year Confidential and Proprietary 3
The Equifax Difference Our data security, award- winning technology, and senior leadership’s commitment to our ACA business sets us apart from other vendors. Data Security Technology Commitment • Security certifications • N-Version programming to • Growing our ACA product • ISO 27001 certified ensure accuracy line and client base is one of • 3 rd party legal audits to our top 5 corporate initiatives • SSAE 16 report • Relationship with CMS, IRS, ensure compliance • FISMA certification from • Built on proven data and other government the government agencies further establishes analytics platform • Security team of 200+ us in the ACA compliance • Award-winning employees space • Already releasing 2 nd • Continuous education and generation platform training of employees Confidential and Proprietary 4
2015 Year in Review Confidential and Proprietary 5
ACA Evolution 2017 2016 2015 ??? Workforce Planning IRS Reporting Legislative Changes Compliance 2014 Forms Submission / Dispute Resolution Eligibility Risk Mitigation Lookback / Monthly Measurement Confidential and Proprietary 6 6
2015 – Key Issue: King vs. Burwell Confidential and Proprietary 7
2015 Eligibility Observations 68% ~5% <20% percentage of employees that percentage of variable Enrollment rate for variable were designated as variable employees that were employees that were offered hour in 2015 measured full-time in 2015 coverage Confidential and Proprietary
2016 Key Issue - Election: Confidential and Proprietary 9
Challenges facing Employers Confidential and Proprietary 10
2016 Challenges for Employers Confidential and Proprietary 11
Regulatory Changes... ACA changes and updates to keep on your radar in 2016: 95% is the new 70% 50 is the new 100 Tax Form Changes Excise Tax, FLSA ? IRS fines ? No Extension / Self Certify Confidential and Proprietary 12
Keys to Success in 2016 Data is Everything! The importance of data quality & common Employee challenges to understand and avoid Form 1095/1094 Reporting Communications Two forms to rule them all! What’s new What’s this form? Why did you appeal for 2016. my subsidy?? Anticipating and addressing these questions and more. 02 04 05 01 03 Subsidies & Appeals When employees collect premium tax credits (subsidies), the impact on you as the employer can be significant. Monitoring Monthly Compliance Why you can’t afford to wait until the end of the year to monitor and manage risk Confidential and Proprietary
Keys to Success in 2016 Data is Everything! The importance of data quality & common Employee challenges to understand and avoid Form 1095/1094 Reporting Communications Two forms to rule them all! What’s new What’s this form? Why did you appeal for 2016. my subsidy?? Anticipating and addressing these questions and more. 02 04 05 01 03 Subsidies & Appeals When employees collect premium tax credits (subsidies), the impact on you as the employer can be significant. Monitoring Monthly Compliance Why you can’t afford to wait until the end of the year to monitor and manage risk Confidential and Proprietary
Chaos of Compliance – Summary 3 rd Party Union 1/31 3/31 Retiree COBRA Subsidy Info Confidential and Proprietary
Anticipate Data Complexities The only constant is change Common Data Challenges • Benefit Transactions and Effective Dates • Leave of Absence • COBRA / Union / Retirees • Pay Data w/ Multiple FEINs • Dependents • Static Data 16 Confidential and Proprietary
Additional Challenges Change in Systems Change in Providers HRIS Change in Staff New Requirements Payroll Benefits Historical Access 17 Confidential and Proprietary
Data Management: Vender Solution Confidential and Proprietary
Data Management: Summary Schedule regular meetings with all data stakeholders to prevent delays or disruptions Perform regular spot checks to ensure accuracy and make year-end validation and reporting easier Ensure regular transmission of all data from 3 rd party providers. If planning to implement a new payroll, HRIS, or benefits platform, make sure you understand how it impacts ACA compliance. Confidential and Proprietary
Keys to Success in 2016 Data is Everything! The importance of data quality & common Employee challenges to understand and avoid Form 1095/1094 Reporting Communications Two forms to rule them all! What’s new What’s this form? Why did you appeal for 2016. my subsidy?? Anticipating and addressing these questions and more. 02 04 05 01 03 Subsidies & Appeals When employees collect premium tax credits (subsidies), the impact on you as the employer can be significant. Monitoring Monthly Compliance Why you can’t afford to wait until the end of the year to monitor and manage risk Confidential and Proprietary
4980H Penalties Assessed Monthly Know your risk exposure and avoid year-end surprises. 4980H(a): The “A” fine 4980H(b): The “B” fine • Who’s liable: ALEs who fail to • Who’s liable: ALEs who fail to offer offer MEC to 95% of FT affordable, minimum value employees and have at least one coverage to any FT employee who FTE who qualifies for a subsidy qualifies for a subsidy • Penalty: $2,160/year per full-time • Penalty: $3,240/year for each employee eligible EE not offered • Assessed monthly: $180 per • Assess monthly basis: $270 per month month 19 Confidential and Proprietary
The “C” Penalty - The Hidden Penalty While not an actual fine, the cost to cover an employee who was inaccurately determined as full time can be substantial. The average family premium is $16,655 per year* (Employee = $4,518, Employer = $12,137). Just 10 mistakes a year can be costly 10 X $12,137 = $121,370 *Source: Kaiser Family Foundation 2 2 Confidential and Proprietary
Why Monthly Monitoring is Key - Example Example: John was hired by the hospital but is not employed until October 20 th , and will not be eligible for coverage until February 1, 2017. Part II Employee Offer and Coverage 2017 All 12 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan Feb Mar Months 14 Offer of Coverage (enter 1H1 1H 1H 1H 1H 1H 1H 1H 1H 1H 1H 1H 1H 1H 1E required code) 15 Employee Share of Lowest Cost Monthly Premium, $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ for Self-Only Minimum Value Coverage 16 Applicable X X X X Section 4980H Safe 2D - 2A 2A 2A 2A 2A 2A 2A 2A 2A 2B 2D 2D 2C Harbor (enter code, if applicable) NOTE: John would not receive a 1095c since he was never a FT employee for the year and was never on the Exception: If you fail to offer coverage on time in February, the Limited Non-Assessment period is vacated and he would company’s health plan. be measured monthly Oct-Dec which could create a FT status and necessitate a tax form. A penalty could also apply. 23 Confidential and Proprietary
Compliance: Vended Solution Regular monitoring mitigates risk and reduces penalties. Know your risk! 24 Confidential and Proprietary
Monthly Compliance: Now What? Assess internal readiness; do you have the data and tools in place to monitor monthly results? Develop an internal communication plan, ensuring that clean ownership is established among stakeholders and leadership Have policies in procedures in place for risk mitigation (e.g. what actions will be taken if compliance results fall below the desired threshold) Confidential and Proprietary
Keys to Success in 2016 Data is Everything! The importance of data quality & common Employee challenges to understand and avoid Form 1095/1094 Reporting Communications Two forms to rule them all! What’s new What’s this form? Why did you appeal for 2016. my subsidy?? Anticipating and addressing these questions and more. 02 04 05 01 03 Subsidies & Appeals When employees collect premium tax credits (subsidies), the impact on you as the employer can be significant. Monitoring Monthly Compliance Why you can’t afford to wait until the end of the year to monitor and manage risk Confidential and Proprietary
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