I RS Reporting - 2016 1095C / 1094C October 14, 2015
I RS Reporting - 2016 Will Compton VP of Marketing Capital Benefit Services wcompton@capitalbenefitservices.com
WARNI NG!!
This stuff is really important! Hang in there…..
What is going on here? The Affordable Care Act (ACA) imposes new reporting responsibilities on employers starting with the 2015 calendar year. The reporting is similar to the current Form W-2 in that an information return 1095-C will be prepared for each applicable employee, and these returns will be filed with the IRS using a single transmittal form 1094-C. What is the IRS looking for? The IRS will use the information to determine whether employees are subject to the new penalty for not having health coverage or…..are eligible for premium tax credits on insurance purchased through the health insurance marketplace. The information will also allow the IRS to determine if an employer is liable for a shared responsibility penalty.
How to determine if this applies to you or not? Applicable large employers are those that had, on average, at least 50 full-time employees (including full-time equivalent employees) during the preceding calendar year. Full-time employees are those who work, on average, at least 30 hours per week or 130 hours a month Employers need to look at 2014 hours in order to determine 2015 Full Time Status ( any consecutive 6 months ) Seasonal, Part Time, Variable Hour, Temporary… Look Back Measurement Periods
OKAY LETS GET GOI NG
1095-C Part I Lines 1 – 13 Basic Employer & Employee I nformation Part I I Lines 14 – 16 Offer, Coverage & Cost I nformation Part I I I Lines 17 – 22 Covered I ndividuals I nformation
EMPLOYEE INFO 1. Must be provided to any employee who worked full time for you in any month throughout the year. 2. Must be provided to any employee who worked full time for you in any month throughout the year, even if they waived coverage. EMPLOYER INFO
Question # 14: Offer of Coverage (enter required code) • You must enter one of 9 possible codes for each month of the year. • You may enter 1 code in the “All 12 Months” box if the code is the same for all 12 months of the year. OFFER OF COVERAGE CODE
9 Possible Codes for Line 14 (1A – 1I ) 1. 1A. Qualifying Offer: Minimum essential coverage providing minimum value offered to full- time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and at least minimum essential coverage offered to spouse and dependent(s). 2. 1B. Minimum essential coverage providing minimum value offered to employee only. 3. 1C. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) (not spouse). 4. 1D. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to spouse (not dependent(s)). 5. 1E. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse. 6. 1F. Minimum essential coverage NOT providing minimum value offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents. 7. 1G. Offer of coverage to employee who was not a full-time employee for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the calendar year. (COBRA) 8. 1H. No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage). 9. 1I . Qualifying Offer Transition Relief 2015: Employee (and spouse or dependents) received no offer of coverage, received an offer that is not a qualifying offer, or received a qualifying offer for less than 12 months.
1A – Qualifying Offer Minimum essential coverage providing minimum value offered to full-time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line (FPL) and at least minimum essential coverage offered to spouse and dependent(s). In order to meet the mainland FPL affordability test the employee’s monthly cost of coverage for the employer’s lowest cost MV/MEC plan can be no more than $93.17 per month in 2015.
1E – MV/ MEC Offer of Coverage Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse. For most employers that offer coverage – this will be the most common code used.
1H – No Offer of Coverage No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage). This code may be used often – especially during a new FT EE’s waiting period and first year of employment if on a measurement period.
Question # 15: Costs of: Employee’s share of the Monthly premium for Employee-Only coverage of the lowest cost plan you offer 1. You may enter 1 amount in the “All 12 Months” box if the EE cost is the same for all 12 months of the year. 2. Leave blank for months in which no offer of coverage is made. COST TO EMPLOYEE
Question # 16: Applicable Section 4980H Safe Harbor (enter code if applicable) You may enter one of 9 possible codes for each month of the year – only if applicable. Leave blank if no safe harbor code applies. You may enter 1 code in the “All 12 Months” box if the code is the same for all 12 months of the year. SAFE HARBOR CODE
9 Possible Codes for Line 16 (2A – 2I ) 1. 2A. Employee not employed during the month. 2. 2B. Employee not a full-time employee. 3. 2C. Employee enrolled in coverage offered. 4. 2D. Employee in initial waiting period, measurement period, etc. 5. 2E. Multiemployer interim rule relief – Union employees 6. 2F . Section 4980H affordability Form W-2 safe harbor. (if used, must use for all months coverage offered) 7. 2G. Section 4980H affordability federal poverty line safe harbor (may use for any month eligible, but waived) 8. 2H. Section 4980H affordability rate of pay safe harbor. (may use for any month eligible, but waived) Note calculated off of 130 hours per month. 9. 2I. Non-calendar year transition relief applies to this employee.
Lets look at some examples
• John has worked at XYZ Company for 2 yrs. • His plan is affordable based on his salary. • He covers himself and his dependents are offered the chance to enroll for the entire calendar year. 1E – Employee was offered coverage for the entire year EE Cost for Self Only Coverage Lowest cost plan 2C – EE enrolled in plan for entire year
Full Time Employee Hired March 1 st 2015 • • Employee enrolled, dependents offered the chance to enroll • Waiting Period –1st month after 30 days • Plan costs $100 a month 1E – MV/MEC Offer of 1H – Not Cost of plan Coverage employed yet 2D – Waiting period 2A – Not employed yet 2C – Employee enrolled in coverage offered
1A – Employee was 2C – Employee enrolled offered coverage for in coverage offered the entire year 2G – employee waived coverage Full Time Employee / Waived Coverage at Open Enrollment • Plan Anniversary 7/ 1 • Employee and dependents eligible to enroll. • FPL Safe Harbor -$50 per month
Retiree / COBRA Covered All 12 months of Year Assumptions Plan anniversary 1/ 1 1G – offer of coverage – employee not full time
1E – MV/MEC Offer of 1H. No offer of Coverage coverage 2E. Multiemployer 2A. Employee not interim rule relief. employed during the month. Union employee covered by a multiemployer plan Homer belongs to the Local 123 (union). He started to work at Springfield Nuclear on 7/ 1/ 2015. Homer is eligible for – and participates in – Local 123’s multiemployer health plan. Springfield Nuclear is required to contribute towards the cost of Homer’s coverage under a collective bargaining agreement.
Part I I I – Self I nsured Employers Only Covered I ndividuals (Dependents) • 1095-C Part III is for employers with self insured coverage only! • Need to add info for any covered dependents. • Name, SSN & Months Covered. • (If SSN is not available a DOB may be used after at least 1 initial + 2 documented attempts to get the SSN.)
Hang in there….. wow…..
1094C Part I Basic Employer I nformation Part I I Understanding Controlled Group Status Total Number of 1095C filed Yes, these can be Certifications the same number of Eligibility
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