ACA Update and 2016 Readiness Wednesday, November 11, 2015, 2:00pm–3:00pm EST

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Joe DiBella Executive Vice President of the Health & Welfare Practice

Conner Strong & Buckelew

Phyllis Saraceni Senior Vice President, Compliance & Audit Practice Leader

Conner Strong & Buckelew

Today’s Speakers

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Conner Strong & Buckelew’s next installment in ongoing series of webinars on key national healthcare reform issues

Recent updates

Fees and assessments

Final IRS reporting forms and process

- Data needed to complete the forms (1094 and 1095)

- Pay-or-play full-time tracking

- Timing, penalties, extensions, waivers

- Medical plan eligibility definition

Federal Exchange notices

Welcome and Agenda

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Will this webinar be available after the presentation date? Yes. We send all registrants a link to recording after live session.

You may also access an archive of all webinar recordings by visiting our Webinars Page on the Conner Strong & Buckelew website.

Individuals who were unable to attend live webinar may listen to recording.

Please feel free to share these resources with friends and colleagues who were unable to attend this live presentation.

Participant Question

ACA: Recent Updates

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Political and Social Landscape

Five years after enactment, ACA implementation continues

Third open-enrollment period for Exchange coverage began last week

About 35 million people in U.S. remained without insurance in 2015, according to Congressional Budget Office, despite law intended to cover nearly all legal residents

Despite major outreach efforts by Obama administration

government’s data showed that six in 10 people still unaware tax credits available to help them purchase health insurance

Americans remain uninformed about availability of Exchange coverage

employers remain unaware of the full effect and responsibilities related to the employer mandate

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Political and Social Landscape

Challenges Continue

• June 2015 Supreme Court decisions found subsidies legal Supreme Court to next hear case in 2016 on religious controversy over

contraceptive/abortion coverage under employer sponsored health care fourth legal challenge to the law since Obama signed the ACA in 2010

Repeal Efforts ACA is all but assured to survive until at least end of President Obama’s

term President continues to promise veto of any wholesale changes to ACA

Enthusiasm for total repeal/replace of ACA has waned as many Republicans believe that even partial repeal is unacceptable presidential candidates Rubio and Cruz have said they will not support

bills that only partially repeal ACA as they promised in campaigns to undo it entirely

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Political and Social Landscape

Looking ahead

In October, House approved bill that would repeal significant ACA provisions, including Cadillac tax and individual and employer mandates. Many feel the bill is expected to clear congressional hurdles and be presented to President for signature. President is not expected to sign it.

GOP getting ACA repeal bill through both houses of Congress would send message to public that it will be able to undo ACA in 2017 if there is a Republican in White House

Still could be some opportunities for continued changes in short term (streamline ACA reporting, change ACA definition of FTE, repeal ACA medical device tax)

repeal of Cadillac Tax looks likely

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Automatic Enrollment Repealed

• Recent budget bill signed by President includes complete repeal of automatic enrollment requirement.

• Would have required employers with more than 200 FTEs to automatically enroll new FTEs in health plans (with adequate notice and an opportunity for employees to opt out).

• Implementing regulations never issued, so employers never had to comply with the requirement.

• Repeal removes significant administrative burden from employers.

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What is the status of the insured plan nondiscrimination rules? Are insured plans required to comply with them, and if so, when?

ACA rule - fully insured plans will be subject to nondiscrimination rules like those applicable to self insured plans

Doesn’t apply to grandfathered health plans

Originally, effective first plan year on or after 9/23/10 – but delayed until further notice

Effective date of any final rules will be prospective to allow time to implement required changes

Participant Question

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Fee is paid on a calendar year (rather than plan year) basis.

Contributions required for three years - 2014, 2015 and 2016 benefit years

$63 per member per year (PMPY) in 2014 $44 PMPY in 2015 $27 PMPY in 2016

Submit Form, enrollment counts and schedule payment by 11/16/15

Payment options for 2015 calendar year -

$44/covered life by 1/15/16, or 2 payments/year: $33/covered life due 1/15/16 and $11/covered

life due 11/15/16

Transitional Reinsurance Payment (TRP) Fee

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Can the Cadillac Tax be passed onto employees? Maybe.

Cadillac Tax = Nondeductible 40% excise tax effective beginning 1/1/18

Employers are free to determine percent of employee contribution/premium share for access to component benefit (subject to discrimination and other rules).

There is no requirement for employer to justify employee benefit contribution/share amount.

Note: With respect to self insured plans, because tax is imposed upon employer and/or plan administrator, and not plan itself, extent to which any tax liability could be charged back to plan is unclear.

Participant Question

Employer Mandate Penalties and Recordkeeping & Reporting

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1. “Pay or Play” Penalties ($2,000/$3,000 failure to offer penalties, FTE determinations, 70%/95%, minimum value, affordability, etc.)

2. Reporting and Recordkeeping (tracking, reporting, form production, employee statements, failure to file penalties, etc.)

Important Concepts

- MV and Affordability - ALE Status/Common Control/Controlled Group Status - Transition Relief for Non-calendar Year Plans - Eligibility vs Workforce Management (Plan Eligibility Language, FTEs

Defined, Measurement Methods)

- Collection of Social Security Numbers

Access past webinar recordings for background and more information

Visit our Webinars Page on Conner Strong & Buckelew website

Two ACA Provisions

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Largest information reporting obligation expansion since the Form W-2

Estimated 700+ million ACA tax forms to be filed with IRS

If an employer fails to provide required reporting form, a penalty of up to $250/form may be imposed with total exposure up to $3M employer

Penalties can be avoided this tax year only if a “good faith effort” to comply can be established

Most organizations are unfamiliar with tax form reporting on this scale and the amount of time and costs it will take to implement

With this significant tax information reporting expansion, there are limited number of tax filing vendors that have experience and many do not have capacity

Quote from prominent ACA reporting vendor on limits to their capacity to assist: “The reality is a very large % of America is not ready with these things – and, while that’s not comforting to you, you are among the majority.”

ACA Reporting Requirement

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Participant Question

How can Conner Strong assist its clients in meeting this requirement?

• Develop plan design strategies (MV, affordability)

• Calculator tools (pay or play projections, Cadillac tax, etc.)

• Education on compliance issues (Webinars, Updates, compliance/checklist support)

• Strategic advisory

• Industry knowledge of recordkeeping and reporting vendors offering systems and tools to provide year-end tax reporting (stand-alone options, payroll options, sophisticated ACA vendor options)

Employers need expert tax and legal advice and systems to track compliance, populate and deliver employee reports, and ensure proper and timely delivery

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What options do ALE's have when they want to fully comply so as to have no ACA penalty but the carrier won't write or renew leaving the ALE without a health plan that they can offer to their FTEs because they cannot meet the minimum participation levels required by carriers? We don’t see this as likely outcome in group market as carriers must offer plans that comply with ACA (affordability issues rest with ALE).

Highly unlikely a major carrier would not offer plans that provide prerequisite coverage levels.

In small group and mid sized markets that are largely fully insured, carriers are offering large variety of plans that offer needed coverage levels. Benefit advisors like Conner Strong & Buckelew can assist with these issues.

Participant Question

Focus on ACA Reporting

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ALE Status – not as easy as it seems (basis of filing obligation)

- Based on FT and equivalents (50 or more)

- Look at prior calendar year, and make determination each year

- Controlled group rules apply (reporting for “Aggregated ALE Group”, “ALE Members”, “Authoritative Transmittal”, as applicable)

- Special rules for 2015, including one-year pay or play delay for medium-sized employers (must still report)

Rules are extremely fact specific, require review/analysis by each affected employer to determine specific application to any business – VENDOR WILL NOT DO THIS FOR YOU

Internal finance and tax/legal advisors should know related employer status

Determine Need to File (ALE Status)

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Would a company consider employees under a collective bargaining agreement as eligible employees when determining small or large business status? Yes. All common law employees, including employees under a collective bargaining agreement, would be considered when determining small or large business (ALE) status. There is a special rule for counting seasonal workers and certain individuals (primarily veterans covered by Tricare or VA health care) may be disregarded.

See https://www.irs.gov/Affordable-Care-Act/Employers/Determining-if-an-Employer-is-an-Applicable-Large-Employer

Participant Question

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Employer Size Penalty and Reporting Chart

Employer Size 2015 Plan Year 2016 Plan Year and Beyond

1-49 FTEs • Penalty and Reporting do not apply • (but Reporting applies if self insured)

• Penalty and Reporting do not apply • (but Reporting applies if self insured)

50-99 FTEs

• Penalty does not apply (must certify not reducing size of workforce to stay below 100 FTEs)

• Reporting applies

• Penalty applies (must offer coverage

to 95% of FTEs and dependents to age 26)

• Reporting applies

100 or more FTEs

• Penalty and Reporting apply • Employer must offer coverage to 70%

of FTEs and dependents to age 26

• Penalty and Reporting apply • Employer must offer coverage to 95%

of FTEs and dependents to age 26

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Penalties for Failure to Report

The increased penalty amounts are as follows:

Penalty Type

Per Violation

Annual Maximum

Annual Maximum for Employers with ≤$5

Million in Gross Receipts

Old

Amount

New

Amount

Old

Amount

New

Amount

Old

Amount

New

Amount

General

$100

$250

$1.5 million

$3 million

$500,000

$1 million

Corrected within 30 days

$30

$50

$250,000

$500,000

$75,000

$175,000

Corrected after 30 days, but before Aug. 1

$60

$100

$500,000

$1.5 million

$200,000

$500,000

Intentional disregard

$250*

$500*

None

N/A

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Determine What to File MEC (B Form) 6055 Reporting

Forms 1094-B and 1095-B

Information reported on 1094-B (IRS transmittal) and 1095-B (individual statement) confirms each person’s MEC enrollment for each month of coverage as required by individual mandate

Every entity that provides MEC to individual during calendar year must file information return and transmittal

Insurers will file 1094-B and 1095-B for all insured employer coverage Small employers (under 50) who self insure their group health plans will

file 1094-B and 1095-B Multiemployer plans will report coverage to enrolled employees on Form

1095-B (individual statement) and employer should not complete Form 1095-C (Part III) for those employees

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Determine What to File Large Employer (C Form) 6056 Reporting

Forms 1094-C and 1095-C

Information reported on Form 1094-C (IRS transmittal) and 1095-C (employee statement) confirms employer’s compliance with employer mandate and confirms MEC enrollment as required by individual mandate

• An ALE member (over 50) completes 1095-C Parts I and II for each FTE (whether or not offered coverage) for any month of calendar year Employers with self insured plans complete the entire form for any

individual (FTE, non-FTE, employee family members, COBRA, retiree, and others) who enrolled in self insured plan

Employers with fully insured plans/multiemployer plans complete Parts I and II only for FTEs covered by fully insured/multiemployer plan; insurer/multiemployer plan files 1094-B with IRS and 1095-B with employees who enrolled in fully insured/multiemployer plan

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Type of Entity “B” Form Filing? “C” Form Filing?

Small employer (less than 50) who self- funds group health coverage

Yes- to report MEC provided under group health plan

No- not an ALE, so not subject to 4980H, so not subject to 6056

Small employer (less than 50) who sponsors insured coverage

No- the insurer will have the 6055 reporting requirement

No- not an ALE, so not subject to 4980H, so not subject to 6056

Large employer who sponsors insured coverage

No- the insurer will have the 6055 reporting requirement

Yes- an ALE, so subject to 4980H, so subject to 6056

Insurer of employer- sponsored group health coverage

Yes- the insurer will have the 6055 reporting requirement

No- insurers don’t report for ALEs under 6056

Large employer who self- funds group health coverage (and provides coverage to certain non-employees)

Maybe- employer has option of reporting MEC provided to non- employees on either “B” or “C” Forms

Yes- subject to mandatory combined reporting so 6055 and 6056 reporting for employees and FTEs will be on “C” Forms

Which Form to File

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ABC is an ALE (over 100 FTEs) and sponsors SI plan for all employees, and offers FI plan underwritten by BigCo Insurance to employees in the PA/NJ/DE tri-state area. Some employees enroll in SI coverage and some enroll in FI coverage.

ABC will file Forms 1094-C/1095-C, and BigCo will send Form 1095-B to employees enrolled in FI coverage.

For FTEs: If enrolled in NO coverage, ABC will complete Parts I and II of Form 1095-C and

leave Part III blank If enrolled in SI coverage, ABC will complete all of Form 1095-C If enrolled in FI coverage: ABC will complete Parts I and II of Form 1095-C and

leave Part III blank; BigCo will complete Form 1095-B For non-FTEs: If enrolled in NO coverage, then no reporting by ABC or BigCo If enrolled in SI coverage, ABC will complete all of Form 1095-C (with Part II coded

for non-FTE status) If enrolled in FI coverage, ABC will complete no Form 1095-C; BigCo will complete

Form 1095-B

Example

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If I only offer fully-insured coverage do I have to complete a Form 1095-C? Probably.

If you are ALE Member (over 50) you must complete 1095-C Parts I and II for each FTE for any month of calendar year whether or not you offer coverage If ALE Member only offers fully-insured coverage then ALE Member does not complete Part III of Form 1095-C.

Fully insured carriers provide Form 1095-B to report actual coverage for each month of 2015.

Participant Question

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I have been told I have to file a Form 1095-C even for my part-time employees. Is that correct? Maybe.

• An ALE Member (over 50) must complete 1095-C Parts I and II for any employee who was FT (whether or not offered coverage) for any month of calendar year

So if PT from 1/1/15 to 11/30/15 and FT from 12/1/15 to 12/31/15 then ALE Member must complete Form 1095-C for that employee

• Any employer with a self insured plan must complete the entire Form 1095-C for any individual (FT, PT, employee family members, COBRA, retiree, and others) who enrolled in the self insured plan

So if PT enrolled in self insured plan for any month of 2015 then employer must complete a Form 1095-C for that employee

Participant Question

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Do we have to issue 1095s to employees who were offered but waived insurance and received a waiver (opt-out incentive amount) instead?

• If employee was FTE then yes, ALE member has to complete 1095-C for every FTE, whether or not they were offered coverage for any month of calendar year, and whether or not they waived coverage or received a waiver

• If the employee was not a FTE and did not enroll in self insured coverage for any month of the year then no, ALE member does not need to complete 1095-C for employee

Participant Question

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Both B and C forms involve reporting to IRS and providing statements to employees - similar to how Forms W-2 are provided 1095-C to employee (can be sent by mail, hand-delivery, or electronic) Must be

addressed and mailed (postmarked) on or before 2/1/16; Special rules apply for electronic distribution; 30 day maximum extension of time can be filed (postmarked) on or before the due date (but it must be approved by the IRS; it is not granted automatically). Extension application letter must be sent fully explaining reason for requesting extension.

1094-C/1095-C to IRS (electronic filing is required for all ALE members who file at least 250 Forms) paper filing due 2/29/16; electronic filing due 3/31/16; extension requested using Form 8809 (online fill-in form available or can mail or fax) due if filed on paper by 2/29/16; if electronically by 3/31/16 (cannot be filed earlier than 1/1/16). Second extension of not more than 30 days may be requested. Electronic filing hardship waiver (requesting to file by paper rather than electronic) available if requested by 1/14/16. Two cost estimates for software, programming, or third-party services for preparation of electronic files must be attached to waiver request.

When to File Extensions and Waivers

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To determine ALE Member’s exposure under “substantially all” $2,000 penalty, the IRS will look at Form 1094-C, Part III.

Penalty Exposure Indicated on Form 1094-C

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• Form 1094-C, Part III, Column (b) asks for “Full-Time Employee Count for ALE Member”

• Column (c) asks for the “Total Employee Count for ALE Member.”

- Note that employee in Limited Non-Assessment Period (in waiting period or in measurement period) would not be reported in Column (b) as FTE, but would appear in Column (c).

• If employer indicates “No” at Column (a), failed to offer MEC to substantially all (70% in 2015, 95% in 2016) of its FTEs, and if at least one of these employees qualified for premium tax credit or a cost-sharing subsidy, employer would owe $2,000 penalty based on number of FTEs reported in Column (b); minus 80 in 2015 (goes to minus 30 in 2016).

Penalty Exposure Indicated on Form 1094-C

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My ACA vendor wants me to identify the plan start date and measurement periods. How do I answer these questions? Controlled group/ALE determination, plan year issues and FTE and eligibility measurement period issues are all relevant for purposes of penalty exposure and reporting process.

Each individual ALE Member must separately file its own Form 1094-C and indicate FTEs (measured over measurement periods) and penalty exposure for each month of 2015.

Answers to these questions should be provided based on what actually occurred during those months and through the coding process on Form 1095-C each ALE Member must indicate whether FTEs were offered coverage for every month of the year, or if not, whether they were otherwise in a limited non-assessment (measurement) period for penalty purposes.

Participant Question

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To determine employer’s exposure under $3,000 penalty, IRS will look at Form 1095-C, Part II, Lines 14, 15 and 16

- Completion of Part II codes will likely require considerable employer input even if sophisticated ACA technology vendor is assisting with form production

- Employers will use applicable indicator codes, and depending on code entered, will provide employee’s share of lowest-cost monthly premium for self-only MEC that provides MV

Penalty Exposure Indicated on Form 1095-C

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Line 14 provides details on offer of coverage, type of coverage and to whom it was offered (employee, spouse and/or dependent), and if coverage offered had MV and whether it was affordable

Cannot leave Line 14 blank

Line 14 – Offer of Coverage Codes

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The code listed at line 14 describes coverage offered (or not offered) to a FTE.

• The reporting on Line 14 requires employers to track offers made to employees.

• Most employees will use no more than two or three codes and the appropriate codes will be based on the typical offers you make to your workforce.

• For most FTEs offered family coverage, employers will use code 1E

• Employers will generally enter 1H for an employee in a waiting period (measurement period) for the month

Line 14 – Offer of Coverage Codes

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Line 15 asks for the dollar amount of the employee’s contribution for self-only minimum value coverage.

Line 15 only applies to employees that the employer claims was offered a qualified health plan on Line 14.

So Line 15 will show an amount only if code 1B, 1C, 1D, or 1E is entered on line 14.

Line 15 – Affordability Code

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We have self-insured plans that offer different coverage levels/costs in different states, but the same plan. Do we have to specify on each person’s form the cost of the lowest plan specific to their state or just the lowest plan cost overall? You specify on each person’s form the cost that is specific to that person.

An ALE Member must specify on each person’s form (as required) at line 15 the employee share of lowest-cost monthly premium for self-only MEC providing MV offered by the ALE Member to that employee.

This amount may not be the actual amount paid for coverage if, for example, the FTE choses to enroll in more expensive coverage, such as family coverage.

Participant Question

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In box 15, we are showing the lowest single rate for the coverage which is offered, not the rate that a given employee may be paying for their own coverage. So we anticipate that each person's form will have the same number in box 15. Is this correct? Not necessarily.

If every person has the same options and cost share then each person’s form will have the same number in box 15 (as required).

If each person does not have the same options and cost share (because different divisions or classifications have different benefit offers) then the number in box 15 may vary.

Participant Question

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How is line 15 calculated on Form 1095-C? Can you give an example? There are three safe harbors that an employer may use to determine affordability (Form W-2 wages, an employee’s rate of pay, or the federal poverty line).

Example: Pat is employed from 1/1/15 to 12/31/15. BigCo offers Pat and Pat's dependents minimum essential coverage (MEC) during that period that meets the minimum value (MV) requirements. The employee contribution for self-only coverage is $1,200 for the calendar year. For 2015, Pat’s Form W-2 wages are $24,000. Because the employee contribution for 2015 is less than 9.5% of Pat’s Form W-2 wages for 2015 ($1,200 is 5% of $24,000), the coverage offered is treated as affordable with respect to Pat for 2015.

Participant Question

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What are the implications associated with opt-out incentive programs? Opt-out cash incentives = money employees receive for waiving medical coverage

Suggestion that opt-out amount must be added to employee contribution amount when determining if coverage is affordable. Confusion on this issue based on rules that apply to affordability determination under individual mandate. We understand IRS is considering issuing guidance on this issue very soon and that any guidance issued would be applicable prospectively.

Affected employers should make a decision how to treat these amounts for this year with advice of their legal counsel.

Participant Question

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Line 16 asks for code indicating whether employer has an excuse for failing to offer coverage.

• The code to be listed at line 16 provides IRS information to administer pay or play penalty provisions.

• Code indicates whether under a rule or safe harbor the employer will not be subject to penalty, or that coverage offered will be treated as affordable.

• Line 16 can be left blank if no code applies.

• 2C should be used for any month in which an employee is enrolled in coverage for the entire month. From an ALE Member’s perspective, entering Code 2C provides immunity from the $3,000/employee penalties with respect to FTEs.

Line 16 – Safe Harbor Code

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Line 16 Indicator Codes

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Line 16 - Should there be a code on every form or only if they aren't enrolled in insurance in certain months? For example, if someone is enrolled for the full year do we put code 2C or is that only if it is an employee who has a different code in some months but code 2C in some months? Line 16 can be left blank if no code applies.

Code 2C (actual enrollment in employer’s plan) always takes priority over any other line 16 code for months in which FTE enrolls in employer’s plan. Code 2C priority applies regardless of whether plan is FI or SI — this code relates to potential liability for penalties (and employee’s eligibility for PTC), so although plan’s insurer will file B Forms to report individuals enrolled in FI plan, the employer must know which of its employees are enrolled in the FI plan in order to complete line 16 correctly.

Participant Question

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How are covered retirees and COBRA participants to be handled? If individual was not FT for any month of 2015, but received SI coverage during any month of 2015, ALE would have to provide 1095-C indicating months of coverage and use Code 1G (offer to non-FTE)

COBRA offers for employees terminated during year are not reported as offers of coverage under any circumstances, even if former employee elects coverage. Code 1H (no offer of coverage) on line 14 and code 2A (individual not employed) on line 16 for any month COBRA offer was made to terminated employee. (2A protects employer from potential penalties for month)

Offers of COBRA to active employees (e.g., those who experience reduction in hours and lose coverage) should always be reported as offer of coverage and if employee enrolls in COBRA, employer would enter 2C (enrolled)

In any event, COBRA enrollment (actual coverage) is to be reported by self insured plan at Part III of Form 1095-C, or by insured carrier on Form 1095-B

Participant Question

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Q - What can we expect in terms of compliance auditing? Q - How often will we be audited?

Employers can be audited by DOL for compliance failures, and also by HHS or IRS. As to ACA C form, it’s likely risk of an actual audit is fairly limited as IRS has limited resources.

But IRS will assess and collect penalty payments from employers after C forms are submitted – based on how C forms are completed.

Expect IRS to start notifying employers in 2016 if they are potentially subject to penalties for 2015 after employees’ individual tax returns are processed.

So first notification likely won’t come until late 2016. Employers will have an opportunity to respond to IRS before IRS actually assesses any ACA shared responsibility penalties.

Participant Question

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Continued….

Regarding assessment and collection of payment, IRS states on its website:

“An employer will not be contacted by the IRS regarding an employer shared responsibility payment until after their employees’ individual income tax returns are due for that year—which would show any claims for the premium tax credit.

If, after the employer has had an opportunity to respond to the initial IRS contact, the IRS determines that an employer is liable for a payment, the IRS will send a notice and demand for payment to the employer. That notice will instruct the employer how to make the payment.”

Participant Question

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Employee PTC Notices from Exchanges

Be prepared to start receiving federal PTC Exchange notices in Spring 2016

Employee applies for Exchange coverage and PTC; Exchange determines employee’s eligibility based on information provided by employee; Exchange notifies employer of employees determined eligible for PTC

• Validity of employee’s PTC based on income and offers of coverage; employer will be subject to tax penalty if FT and not offered affordable coverage; notices sent for every employee that receives PTC (even PTEs and other employees who would not make employer liable for tax penalty)

Have procedure in place for dealing with notices; how to determine if Exchange determination of PTC eligibility is valid; how to determine which cases to appeal

Be prepared to appeal notice within 90-day period; employer not required to appeal; initiate appeals process if employee is FT and offered qualified coverage (and therefore not PTC eligible)

Finance/tax department be prepared to handle tax assessment

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Planning for Reporting

Employers required to provide detailed information on workforce hours of service and employee classifications, minimum value and affordability of health coverage offered, and offers of health coverage to FTEs and actual coverage elected

Employers well-advised to ensure they have addressed certain items with tax advisers, legal advisers, human resources, ACA vendors, recordkeeping and reporting process, appeals process, and tax assessment and payment process

Employers and tax advisers struggling with specifics of compliance and data collection

Link here for access to the Forms: https://www.irs.gov/Affordable-Care-Act/Employers/Information-Reporting-by-Providers-of-Minimum-Essential-Coverage

Rules are Incredibly Complex! Significant lack of awareness in employer community

regarding responsibilities High Risk of Penalties

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Self-Audit Considerations

Be prepared. Work with internal tax, accounting, HR and ACA vendors.

Finalize process for completing, reviewing and signing 1094-C and filing it with IRS in March 2016, and 1095-C creation and distribution to employees in January 2016

Evaluate your payroll, HR, and benefits systems to ensure that you have all required reporting information on a monthly basis beginning in January 2015

Create process to respond to IRS Appeals, Exchanges and Premium Tax Credit Notices

Pain points to preparing 1095-C

Combining information from internal payroll/HRIS systems with external plan enrollment rosters - these never seem to agree

Reconstructing payroll and enrollment history from January to current - don't assume it will be easy!

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Agency Resources

Health and Human Services (HHS): http://healthcare.gov/ Department of Labor (DOL): http://www.dol.gov/ebsa/healthreform/ Internal Revenue Service (IRS): http://www.irs.gov/newsroom/article/0,,id=220809,00.html?portlet=6 HCTT-2015-41 IRS webinar (training) series http://content.govdelivery.com/accounts/USIRS/bulletins/10f5c53

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Help from Conner Strong & Buckelew

Conner Strong & Buckelew Healthcare Reform website page at:

http://www.connerstrong.com/healthcare_reform

» News updates

» Online library of client updates and alerts

» Summary of major provisions of the new law

» PPACA videos

» Outline of all aspects of the new law

Check back for updates, news and analysis, and updated tools to help you navigate this complex process

Call Conner Strong & Buckelew at 877-861-3220

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Other Resources from Conner Strong & Buckelew

Periodic Webinars Web-based presentations on health care legislation, regulations and innovative ideas

Email Alerts and Updates High level, quickly produced articles about emerging issues intended to alert clients to legislative and regulatory developments

Perspectives Thought pieces intended to identify trends/ issues, helping clients anticipate challenges Our presentations and publications are for educational purposes only and are not intended, and should not be relied upon, as accounting, tax or legal advice; any advice is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code (IRC) or applicable state or local tax law provisions.

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Thank you for your participation!

Thank You