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The ACA: What Could Go Wrong? @Ellen_Feeney #SHRM15
Major Potholes to Avoid and the Road Ahead Three Potholes to Avoid Notice of Coverage Options Misunderstandings IRS Reporting Requirements by Employer Size The Biggest Pothole of All – the 4980H(a) Penalty Two Stops on the Road Ahead Exchange Notices Excise Tax on High Cost Health Plans (Effective 2018) 1 © Copyright 2015 ADP, LLC.
2 © Copyright 2015 ADP, LLC. Pothole #1 – The Notice of Coverage Options Provide to All New Hires (not just benefits-eligible) Employers Who Offer a Health Plan: Employers Who Do Not Offer a Health Plan:
Pothole #2 - IRS Employer Mandate Reporting Applies to Employers with 50-99 Full-Time Employees Reporting required for all ALEs with 50+ full-time employees Penalties apply if you have 100 or more employees Employers – regardless of size – that offer self-insured plans must do Minimum Essential Coverage Reporting 3 © Copyright 2015 ADP, LLC.
4 © Copyright 2015 ADP, LLC. New IRS Forms Are You Ready for Employer Mandate Reporting? Form 1094-C to the IRS Filing electronically (>250 Forms 1095-C) by March 31 of the next year Filing paper (<250 Forms 1095-C) by February 28 of the next year Form 1095-C to IRS, Full-Time Employees and COBRA Participants and Retirees Mail paper forms to last known address or electronic delivery (with consent) By January 31 of the next year First filing in 2016 for 2015 information
Form Penalties Penalties up to $100/Form 1095-C may apply for missing/incorrect taxpayer identification numbers, late filing, incorrect media, incorrect format, etc., up to $1.5 million. No penalties in 2015 for missing or incorrect information for employers that demonstrate a good faith effort to comply. 5 © Copyright 2015 ADP, LLC.
6 © Copyright 2015 ADP, LLC. Pothole #3Perhaps, the Biggest Pothole of All. . . . Not offering coverage to at least 70% of full-time employees and being subject to Section 4980H(a) penalty! $2,000 times the number of full-time employees For 2016 and after, an Offer of Health Coverage must be made to at least 95% of full-time employees
Stop #1 on the Road AheadEmployer Exchange Notices 7 © Copyright 2015 ADP, LLC. The Exchange must notify the employer when an employee is deemed eligible for a premium tax credit and provide the employer the right to appeal Most state exchanges and the FFE are not yet sending notices Are you prepared to respond?
State Health Insurance Marketplace Types 8 © Copyright 2015 ADP, LLC.
10 © Copyright 2015 ADP, LLC. Thank You and Stay Tuned To ADP’s Eye on Washington regulatory email alerts visit: www.adp.com/eyeonwashington Please visit www.adp.com/acafaqs for a list of ACA Frequently Asked Questions or www.adp.com/health-care-reform for additional ACA insights. Before taking any actions on the information contained in this presentation, employers and plan sponsors should review this material with internal This material is subject to change and is provided for informational purposes only and nothing contained herein should be taken as legal opinion, legal advice, or a comprehensive compliance review. The ADP Logo, ADP, ADP Research Institute, and In the Business of Your Success are registered trademarks of ADP, LLC. All other trademarks and service marks are the property of their respective owners. Copyright © 2015 ADP, LLC. ALL RIGHTS RESERVED. @Ellen_Feeney #SHRM15