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COMPLIANCE OUTLOOK FOR HEALTH AND WELFARE PLAN SPONSORS Where We’ve Been and What’s Ahead in 2016 November 19, 2015

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COMPLIANCE OUTLOOK FOR HEALTH AND WELFARE PLAN SPONSORS Where We’ve Been and What’s Ahead in 2016

November 19, 2015

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TODAY’S PRESENTER KRIS BEALE

Senior Compliance Consultant | EPIC Employee Benefits

Kris provides compliance support for private and public employers on a wide variety of employee benefits matters including the Affordable Care Act, Internal Revenue Code, ERISA, COBRA, HIPAA, municipal ordinances, plan documentation, DOL audits and more. Kris has over 17 years of experience in employee benefits, including HIPAA privacy and security consulting.

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AGENDA Where we’ve been in 2015

– Summary of regulatory and legal developments What’s ahead in 2016

– Federal benefit limits – W-2 reporting of health plan costs – PCORI fees – Transitional Reinsurance Program fees – Employer Shared Responsibility rules – Employer health coverage reporting

Beyond 2016 – Cadillac tax?

Recommended steps for employers Additional resources

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WHERE WE’VE BEEN IN 2015

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SUMMARY OF 2015 REGULATORY & LEGAL DEVELOPMENTS

JAN HIPAA certificates of creditable coverage eliminated

FEB

IRS releases final instructions and forms for ACA health coverage reporting; announces 2016 group health plan cost-sharing limits and clarifies self-only limit applies to each covered person (under self-only or family coverage)

APRIL IRS issues additional guidance about premium reimbursement arrangements (“employer payment plans”)

MAY

Out-of-pocket maximum under HSA-compatible HDHP same for all covered persons in 2016; guidance clarifies preventive services includes contraceptives, cancer screening and more for plan years (PY) starting on or after 7/10/15

JUNE

Supreme Court upholds ACA subsidies in all states; legalizes same-sex marriage nationwide; SBC delivery rules updated, simplified

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SUMMARY OF 2015 REGULATORY & LEGAL DEVELOPMENTS

JULY IRS issues Notice 2015-52, continues process of implementing Cadillac tax, invites public comments

AUG IRS launches “AIR” system for e-filing of Forms 1094/1095

OCT

ACA small group market definition repealed; IRS announces 2016 benefit limits; Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 Act includes benefits-related changes related to veterans and Form 5500 filing extensions; ACA auto-enrollment repealed

NOV ACA guidance on preventive services, wellness, mental health parity; EEOC issues proposed regulations related to GINA and workplace wellness programs

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WHAT’S AHEAD IN 2016

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2016 BENEFIT PLAN LIMITS Health savings accounts (HSAs)

– Maximum contribution: $3,350 self-only/$6,750 family High deductible health plans (HDHPs)*

– Minimum deductible: $1,300 self-only/$2,600 family (no change) – OOP maximum: $6,550 self-only/$13,100 family – “Self-only” limit applies to OOP maximum even if enrolled in family

coverage OOP maximum for essential health benefits (non-grandfathered plans)*

─ $6,850 self-only/$13,700 family ─ “Self-only” limit applies to OOP maximum even if enrolled in family

coverage Qualified Transportation Benefits

– Parking: $255/month – Transit pass/commuter vehicle: $130/month (no change)

* Note: State laws may set different limits for insured plans and HMOs

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SURFACE TRANSPORTATION ACT

Surface Transportation & Veterans Health Care Choice Improvement Act Signed into law September 2015; several provisions may affect employers Military veterans and ALE calculation Allows employers to exclude veterans receiving medical coverage under

certain health care programs provided by the Department of Veteran Affairs (VA) from determination of the employer’s ALE status

May apply retroactively for 2014 (which determines employer’s ALE status for 2015)

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SURFACE TRANSPORTATION ACT (CONT.) Health Savings Accounts and Veterans Starting in 2016, individuals receiving VA benefits for hospital or medical

services for a service-connected disability will not fail to be eligible to receive or make contributions to an HSA

Individuals with other conditions remain ineligible to make or receive HSA contributions if they received VA-administered care in preceding three months (other than certain preventive services)

Form 5500 extension deadline For PYs starting on or after January 1, 2016, the automatic extension of

time to file Form 5500 is lengthened to 3½ months, up from 2 ½ months ─ Example: PY ending December 31, 2016 may obtain an extension to file

by November 15, 2017 to file the Form 5500 (instead of October 15)

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W-2 REPORTING OF HEALTH PLAN COSTS

W-2 reporting - Employers (insured or self-funded) must report the value of group

health coverage on employee’s W-2 (Box 12, Code DD) - Reporting is informational only; no tax consequences – Employers who filed fewer than 250 W-2s for 2014 are exempt from the

health coverage informational reporting requirement for 2015.

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PCORI FEE Patient-Centered Outcomes Research Institute (PCORI) Fee - Applies to all group health plans, unless primarily “excepted benefits” - Carrier pays for insured plans; plan sponsor pays for self-funded plans

o If employer sponsors an insured medical plan integrated with a self-funded plan, employer pays fee for self-funded plan and insurer pays fee for insured plan (e.g. HRA integrated with insured major medical plan); if two or more self-funded coverages are integrated by same employer (e.g., HRA and prescription drug plan integrated with major medical plan), the employer pays the fee once with respect to the entire integrated self-funded plan

- Applies annually for each plan year ending after September 30, 2012 and before October 1, 2019

- Fee is reported and paid once a year, by July 31 following the calendar year in which the plan year ends

- $2.08 per covered life (for plan year ending between 10/1/2014 and 9/30/2015) or $2.17 (for plan year ending between 10/1/2015 and 9/30/2016)

- Example: For plan years ending between October 1, 2015 and December 31, 2015, $2.17 per covered life fee is due by July 31, 2016

- Report and pay fee using Form 720 (Quarterly Federal Excise Tax Return)

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TRANSITIONAL REINSURANCE PROGRAM (TRP) FEE

Annual fee applies to health plan coverage that provides “minimum value” (other than “excepted benefits,” integrated HRAs, health FSAs, or carve-out drug plans)

Carrier pays for insured plans; plan sponsor pays for self-funded plans Temporary program – 2014 to 2016

─ 2014 contribution = $63 per covered life ─ 2015 contribution = $44 per covered life ─ 2016 contribution = $27 per covered life

Employer schedules payment due dates when calendar year enrollment count is reported to CMS – Enrollment count reports for 2015 due November 16, 2015 – 2 payment options for 2015 contributions: o Pay in full ($44.00) by January 15, 2016 o Pay in 2 parts: $33.00 by January 15, 2016 and $11.00 by November

15, 2016

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EMPLOYER SHARED RESPONSIBILTY RULES (‟PLAY or PAY”)

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EMPLOYER SHARED RESPONSIBILITY RULES Background

An ‟applicable large employer” (ALE) that fails to offer minimum essential coverage (‟MEC”) to full-time (FT) employees and their children (to age 26) may be subject to a penalty if a FT employee enrolls in Marketplace coverage and receives a premium tax credit (aka “subsidy”) for the coverage under IRC section 4980H(a).

‟A Penalty”

An ALE that fails to offers MEC that is affordable and provides minimum value to FT employees (and their children) may be subject to a penalty under IRC section 4980H(b) if a FT employee receives a subsidy for Marketplace coverage.

‟B Penalty”

An employer may choose to comply (‟play”) with the employer shared responsibility mandate in order to avoid the possibility of “paying” a penalty, which can be substantial

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EMPLOYER SHARED RESPONSIBILITY RULES Who is an Applicable Large Employer (ALE)?

– ALE is an employer with 50 or more FT and full-time equivalent employees (FTEs)

– ALE with 50-99 FT and FTEs that meets certain criteria is exempt from play or pay penalties for 2015

– ALE determination is made on a controlled group basis and based on prior calendar year employee count

– Liability for, and the amount of, the excise tax is computed and assessed separately for each ALE member

– Each ALE member is responsible for its own health coverage reporting BUT: ALEs exempt from play or pay (e.g., 50-99 FTEs) in 2015 must still

report 2015 coverage – no delay. And, all self-funded plans providing MEC have reporting obligations, regardless of number of FTEs

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EMPLOYER SHARED RESPONSIBILITY RULES What is affordable coverage? Employee’s premium contribution does not exceed

9.5% of income – use IRS safe harbors to define employee’s “income”

Applies to employee-only coverage – employer does not have to contribute towards dependent costs

NOTE: “cash-in-lieu” for waiving coverage or “flex credits” may affect affordability if employee can take amount in cash or apply it to non-health benefits

What is minimum value? Plan pays at least 60 percent of total allowable costs No more than 40% paid by participants: co-pays,

deductibles, co-insurance Must provide substantial coverage for in-patient

hospital services and physician services

SAFE HARBORS FOR AFFORDABILITY

9.5% of annual earnings in W-2 (Box 1) divided by 12 months; or

If salaried, 9.5% of employee’s monthly salary. If hourly, 9.5% of 130 hours x rate of pay; or

9.5% of individual federal poverty level (FPL) ($11,770 in 2015) divided by 12 months = (employee contribution cannot exceed $93.18 per month)

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EMPLOYER SHARED RESPONSIBILITY RULES ‟Penalty A”: ALE does not offer minimum essential coverage A non deductible tax penalty may be assessed if the employer does not

offer MEC (generally, any kind of group health coverage that is not “excepted benefits”) to at least the following percentage of its FT employees (and their children to age 26) ─ 70% in 2015 ─ 95%, or, if greater, 5 FT employees starting in 2016 and later

Penalty is triggered as soon as one FT employee receives a subsidy for Marketplace coverage ─ 400% of federal poverty level or lower

$2,000* annual penalty per FT employee in excess of 30 FT employees (determined monthly = $167/mo) ─ 2015: transition relief excludes 80 FT employees *May be indexed for inflation

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EMPLOYER SHARED RESPONSIBILITY RULES ‟Penalty B”: ALE fails to offer plan that provides minimum value and is affordable Applicable large employers may be subject to non-deductible tax penalty

if employer does not offer minimum value at an affordable price to a FT employee

Penalty is triggered as soon as that FT employee receives subsidized health insurance coverage through the Marketplace

$3,000* annual penalty ($250/mo) per FT employee receiving a subsidy for Marketplace coverage due to employer’s failure to offer affordable minimum value coverage

Penalty B cannot exceed Penalty A if Penalty A applies

*May be indexed for inflation

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EMPLOYER SHARED RESPONSIBILITY RULES Who is a ‟Full-time” employee? Full-time employee means an employee who has 30 or more hours of

service per week (130 per month): – Common law standard; includes all W-2 employees (full-time, part-

time, seasonal, temporary, etc.) – Includes salary, hourly, per diem, or commission only employees – Does not include a sole proprietor, a partner in a partnership, or a 2%-

or more S corporation shareholder – Does not include leased employees who are not common law

employees of the employer that receives the services

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EMPLOYER SHARED RESPONSIBILITY RULES What is ‟hours of service”? Hours of service include:

─ each hour for which an employee is paid, or entitled to payment, for the performance of duties for the employer, and

─ each hour an employee is paid, or entitled to payment, on account of a period of time during which no duties are performed due to vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military duty or leave of absence

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HEALTH COVERAGE REPORTING

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HEALTH COVERAGE REPORTING What is the purpose? Employer reporting of health plan and coverage information provides the

Internal Revenue Service (IRS) with the information necessary to administer and regulate various ACA provisions: ─ Individual Shared Responsibility rules – individuals must have minimum

essential coverage (“MEC”) or face potential tax penalties ─ Individual eligibility for a premium tax credit/subsidy for coverage

through a public Marketplace ─ Employer Shared Responsibility rules – ALEs must offer qualifying

health coverage to full-time employees or face potential tax penalties First required for 2015 calendar year information (reports due in early

2016)

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HEALTH COVERAGE REPORTING

The ACA added two new Internal Revenue Code (“IRC” or “Code”) sections: Code Sections 6055 and 6056 Code Section 6055

─ Provides IRS information about individuals enrolled in MEC. Also requires coverage providers to provide individuals with statements about the MEC

─ Most providers of health coverage (insurers, self-funded employers) are required to do this reporting

– Form 1095-B is used for 6055 reporting. Self-funded employers that use Form 1095-C may report the coverage information in Part III instead of using Form 1095-B

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HEALTH COVERAGE REPORTING Code Section 6056

─ Applicable large employers (ALEs) are subject to the ACA’s employer shared responsibility rules (“play or pay”), and may face a tax penalty if qualifying coverage is not offered to full-time employees (as defined under ACA) o Section 6056 provides information to IRS about the coverage offer

made by ALEs to verify compliance and to assist with enforcement of play or pay. Also requires ALEs to provide individuals with statements about the coverage offered by the employer

─ Form 1094-C (transmittal) and Form 1095-C (return/reporting form) are used for 6056 reporting

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HEALTH COVERAGE REPORTING

How & when to furnish statements to individuals Furnish copy of the 1095-C (or 1095-B or a ‟substitute statement”, if

used) to the ‟Responsible Individual” identified on the form by January 31 of the following year – In 2016, statements due to employees February 1 (January 31 is a

Sunday) Statements must be furnished on paper by mail or electronically under

certain conditions ─ If mailed, send to the recipient’s last known address. Can be mailed

with W-2s – A statement may be electronically provided if individual affirmatively

consents to such disclosure in a manner that demonstrates ability to access the electronic statement after receipt of a specific disclosure and other conditions are followed

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HEALTH COVERAGE REPORTING

How & when to file forms with IRS

The returns must be filed with the IRS on or before February 28 (March 31 if filed electronically) of the year following the reporting year ─ In 2016, deadline is February 29 because February 28 is a Sunday

If an employer is required to file 250 or more Forms 1095-B, or 250 or more Forms 1095-C during a calendar year, returns must be filed electronically ─ Can request waiver by submitting IRS Form 8508, Request for Waiver From

Filing Information Returns Electronically, at least 45 days before the due date of the returns

Must use new IRS e-filing system - Affordable Care Act Information Return system (“AIR”)

Details on AIR program website (See “Additional Resources”)

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HEALTH COVERAGE REPORTING Potential penalties for reporting failures Failure to file information return with IRS: $250 per return, $3,000,000

maximum per calendar year Failure to provide correct employee statement: $250 for each statement,

$3,000,000 maximum per calendar year. Increased penalties for intentional disregard of the requirement to provide an employee statement

Short-term relief for 2015: IRS states no penalties for 2015 returns and statements filed and furnished in 2016 if can show good faith efforts to comply with the reporting requirements (specifically, regarding incorrect or incomplete information on return or employee statement)

No relief is provided for reporting entities that cannot show a good faith effort to comply with the reporting requirements or that fail to timely file an information return or furnish a statement to individuals

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HEALTH COVERAGE REPORTING Extensions of Time Filing with IRS Get automatic 30-day extension by submitting IRS Form 8809 on or before

the due date for filing with the IRS After automatic extension, an additional 30-day extension possible under

certain hardship conditions Providing to individuals For a 30-day extension, send letter to IRS ̶ See instructions for 2015 Forms 1094-C/1095-C for more information ̶ Request must be postmarked by date on which statements are due to

individuals

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FORMS 1094-C & 1095-C

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FORMS 1094-C & 1095-C

IRS Form 1094-C ─ Used to report employer summary information to the IRS ─ Think of it as a cover sheet for the individual employee forms

IRS Form 1095-C – Used to report employee-specific information – In general, one is required for: o each full-time employee; and o each covered employee under a self-funded plan o can use to report non-employee coverage (or Form 1095-B)

Both forms are filed with the IRS and a copy of Form 1095 is provided to each full-time employee and/or covered primary enrollee

Final 2015 forms and instructions issued September 16, 2015

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FORM 1094-C

Form 1094-C (“Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns”) 1094-C is used to transmit Forms 1095-C An ALE member must designate one of its Forms 1094-C as the

“Authoritative Transmittal” to report aggregate employer-level data for all FT employees

An ALE member may file Forms 1095-C all at once or in batches If ALE member files Forms 1095-C in batches:

─ One 1094-C transmittal is the “Authoritative Transmittal” with aggregate data for the ALE member

─ The other Forms 1094-C only summarize the Forms 1095-C filed with them

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FORMS 1094-C Form 1094-C—Data required

─ ALE member’s contact information and EIN ─ Number of 1095-C statements attached ─ Authoritative transmittal information o Number of 1095-Cs issued by the ALE member; o Total employees by month; FT employees by month o Whether MEC was offered (or deemed to be offered) to required

percentage of full-time employees (and their dependents) o Eligibility for qualifying offer or qualifying offer transition relief o Eligibility for “50-99” or deduction of first 80 employees for 2015 o Information about ALE members that are part of aggregated ALE

group

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FORM 1094-C: THE TRANSMITTAL FORM

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FORM 1095-C Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) Reports employee-specific information to IRS

– Copy is provided to each full-time employee and any other enrollees – In general, one Form 1095-C per employer is required for each full-time

employee or other enrollee All ALE members complete Parts I and II of Form 1095-C to report

information about a full-time employee and coverage offered (or not offered) and type of coverage offered to full-time employees and dependents

ALE members with self-funded plans generally complete Part III of Form 1095-C to report covered individuals. (Insurers report this information for insured plans, separately on Form 1095-B.)

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FORM 1095-C

Form 1095-C—Data Required Identifying information for ALE member Employee name, address and SSN Employee FT status Employer offer of coverage by month Whether qualifying offer (MEC, MV and affordable; whether offered to

spouse and dependents) Amount of lowest-cost employee-only MV coverage offered If a self-funded plan provides coverage, names of covered individuals

(enrolled family members) name and SSN. Use DOB if cannot obtain SSN after “reasonable efforts”

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FORM 1095-C

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OVERVIEW OF HEALTH COVERAGE REPORTING Type of Reporting Affected Employers Required Information Form

Code 6056 – Applicable Large Employer (ALE) reporting

ALEs (at least 50 FTEs) Insured Plan or No Plan:

ALE member files Form 1095-C, Parts I and Parts II (and not Part III). Insurer, if any, files Form 1095-B

Self-funded Plan: ALE member files Form 1095-C, Parts I, II and III

Terms and conditions of health plan coverage offered to FT employees (helps the IRS administer the ACA’s shared responsibility penalty for large employers)

To IRS: Form 1094-C (transmittal) and 1095-C due 2/28 (3/31 if filed electronically)

To responsible individual: Informational statements (e.g., Form 1095-C) due 1/31

See “Additional Resources” at end of presentation for links to online forms.

Code 6055 – Reporting of health coverage by providers of minimum essential coverage

Small employers with self-funded health plans

Multi-employer plan sponsors Health insurers Note: ALEs that sponsor self-

funded plans are also responsible for 6055 reporting. However, this reporting usually is done in Part III of the Form 1095-C.

Information on each individual provided with coverage (helps the IRS administer the ACA’s individual mandate)

To IRS: Form 1094-B (transmittal) and 1095-B due 2/28 (3/31 if filed electronically)

To responsible individual: Informational statements (e.g., Form 1095-B) due 1/31

See “Additional Resources” at end of presentation for links to online forms.

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CADILLAC TAX

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CADILLAC TAX 40% nondeductible tax on high-cost health coverage starting in calendar

year 2018

─ Generally applies to major medical coverage, HSAs, HRAs, Health FSAs, and on-site clinics; does not appear to apply to “excepted benefits,” e.g. stand-alone dental and vision plans and most EAPs

─ Applies to retiree coverage, multi employer plans, governmental plans that primarily cover civilian employees

Applies to costs in excess of $10,200 for self-only coverage, $27,500 for other than self, employee per year, calculated on a monthly basis

– Higher cost thresholds for certain high risk populations

– Limits include both employee- and employer-paid portions of the cost

Applies to total cost of the plan (i.e., both the employer and employee contributions)

Includes sum of all applicable coverage for an employee

Presenter
Presentation Notes
For taxable years beginning in 2018, the ACA imposes a 40 percent excise tax on high-cost group health coverage. This tax, also known as the “Cadillac tax,” its intended to control health care costs by encouraging companies to choose lower-cost health plans for their employees. It’s also estimated to generate about $87 billion in revenue which is slated to pay for ACA costs. The tax applies generally to medical coverage as well as Health Svg accounts, HRAs, Health FSAs and on site clinics. What we don’t know for sure at this time is whether the tax will apply to wellness programs, excepted benefits such as limited scope dental and vision benefits, EAP programs or certain voluntary benefits such as cancer insurance. ) The tax applies to costs in excess of $10,200 for self-only coverage and in excess for, $27,500 for self plus one or more per employee, calculated on a monthly basis. There are higher cost thresholds for certain high risk populations. The limits apply to the full cost, so both both employee- and employer-paid contributions. Tax applies to the sum of all coverages provided to an employee so you can see how the cost could easily exceed the thresholds.
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CADILLAC TAX All employers are subject to the tax

─ No small-employer exception

─ No church or government plan exception

Tax assessed against “coverage provider”

– Insured plan – insurer pays

– HSA or Archer MSA – contributing employer pays

– Self-insured plan (e.g., medical, HRAs, health FSAs) – “Person that administers the plan benefits” pays

Current guidance indicates excise tax calculation will be determined in a way that is similar to rules for determining COBRA premiums

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CADILLAC TAX Regulations not yet issued

IRS released Notices 2015-16 and 2015-52 to “initiate and inform” the public

Legislation, lobbying, change in administration in 2016 may impact the scope of the tax

Presenter
Presentation Notes
Regulations have not yet been issued, so there are many unanswered questions about the tax. However, the IRS issued notices in 2015 to inform the public & initiate the process of developing Cadillac tax regulations. The notices provide a glimpse into possible approaches and define: what is applicable coverage, how to determine the cost of the coverage, the statutory limits, and some potential exceptions. Next Slide/notes page
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CADILLAC TAX Sample strategies to reduce cost of coverage Change benefits – but don’t trigger “play or pay rules” Increase defined contributions Add more consumer-driven strategies Increase offerings of after-tax, voluntary and excepted benefits Restrict employer contributions or salary reduction to account-based

plans Exclude spousal coverage to reduce cost of family coverage Consider private exchange to encourage employees to move from legacy

high-cost health plans, provide new options to manage health care

Presenter
Presentation Notes
Many questions! When will the IRS release regulations? Will the IRS adjust the excess benefit levels to keep up with medical inflation? What exclusions will be available such as age and gender? Will the Cadillac tax doom certain benefits like Health FSAs? How will the excise tax be administered for non-calendar year plans? Will the tax be repealed? Will it be amended? There will be a change in administration in 2018, and what impact will that have on the Cad tax provisions? In Washington, legislators on both sides continue to be introduced bills that would make changes to the Cad tax In some shape or fashion.
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NEXT STEPS FOR 2016 …AND BEYOND

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NEXT STEPS FOR 2016 AND BEYOND Benefit limits, changes:

– Update benefit offerings and corresponding plan documents/communications to comply with 2016 plan limits (i.e., HDHPs, HSAs, OOP maximums)

– Communicate new HSA eligibility provisions for employees receiving health benefits from the VA due to a service-connected disability

– Amend plan documents/communications to include same-sex spouses as eligible dependents if required/desired

W-2s: Employers that filed 250 or more W-2s in 2014: – Report value of group health coverage on employee W-2s for the 2015 calendar

year by January 31, 2016

Fees: Employers sponsoring self-funded group health plans: – Pay applicable PCORI fees for 2015 by July 31, 2016 – Pay applicable TRP fee for the 2014 calendar year by November 16, 2015.

Report 2015 enrollment count and schedule 2016 payments by November 16, 2015

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NEXT STEPS FOR 2016 AND BEYOND (CONT.) Play or Pay: Employers with 50 or more FTEs subject to transition relief

criteria: – Offer minimum value, affordable coverage to full-time employees and their

children to avoid potential tax penalties

Forms 1094/1095 reporting: Employers with 50 or more FTEs – Coordinate with benefits administration systems, payroll and/or tax preparers

assisting with reporting – Continue planning and testing of forms preparation process – If filing electronically in-house, prepare for AIR system filing – Finalize decisions about how to distribute Form 1095 to covered individuals – Consider extensions and waivers, deadlines – Continue tracking data during 2016 to complete IRS health coverage reporting

in 2017 Cadillac Tax: All employers starting in 2018

─ Watch for additional guidance and regulations from IRS, legislative activity

─ Consider strategies for reducing costs

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Q & A THANK YOU!

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ADDITIONAL RESOURCES

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EPIC INFORMATION/RESOURCES EPIC webinar, ‟ACA Health Coverage Reporting for Employers – Final IRS 2015 Forms &

Instructions” (Oct. 2015): https://vimeo.com/142913298 EPIC webinar, “Cruising Toward the Cadillac Tax” (Sept. 2015): https://vimeo.com/140331225 EPIC Compliance Alert, “Final Forms and Instructions Issued for 2015” (September 2015):

http://epicbrokerscom.c.presscdn.com/wp-content/uploads/2015/05/ComplianceAlert_2015FinalFormsInstructions_0930115_FINAL.pdf

EPIC Compliance Alert, “Airing Now: The ACA Health Coverage Reporting E-Filing System” (August 2015): http://cdn.sparkart.net/edgewoodins/content/pdfs/Alert_ACAPlayorPayMeasurementMethodsIDFTEmployees_01302015_FinalFinalmms.pdf

EPIC Compliance Alert, “ACA Play or Pay: Measurement Methods for Identifying Full-Time Employees” (January 2015) available at http://cdn.sparkart.net/edgewoodins/content/pdfs/Alert_ACAPlayorPayMeasurementMethodsIDFTEmployees_01302015_FinalFinalmms.pdf

EPIC webinar, “Full-Time Employees and the ACA Employer Shared Responsibility Rules” (July 2014): http://vimeo.com/103759499

ACA Compliance Matters newsletters and other webinars posted on the EPIC Knowledge Center website: http://www.epicbrokers.com/employee-benefits

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IRS FORMS/RESOURCES Final instructions for Forms 1094-C and 1095-C (2015):

http://www.irs.gov/pub/irs-pdf/i109495c.pdf Final 2015 Form 1094-C: http://www.irs.gov/pub/irs-pdf/f1094c.pdf Final 2015 Form 1095-C: http://www.irs.gov/pub/irs-pdf/f1095c.pdf IRS Form 8809 (Application for Extension of Time to File Returns):

https://www.irs.gov/pub/irs-pdf/f8809.pdf IRS Form 8508 (Request for waiver From Filing Information Returns Electronically):

https://www.irs.gov/pub/irs-pdf/f8508.pdf AIR program:

– http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/Affordable-Care-Act-Information-Return-AIR-Program

– http://www.irs.gov/for-Tax-Pros/Software-Developers/Information-Returns/Affordable-Care-Act-Information-Returns-AIR-Program-Did-You-Know%3F

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EPIC is an insurance brokerage and benefits consulting firm and does not provide tax or legal advice to clients. Therefore it is important to consult legal counsel regarding this information to determine how it affects your company and what the company needs to do to comply.