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BenefitsACA Compliance Update

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• What’s new to ACA in 2019?

• 2019 ACA Reporting Deadlines

• How to audit data now to avoid most 1095 form errors

• ACA compliance – shared responsibility notices, IRS 226J

• The future of ACA

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What will you learn about today?

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ACA Update -Who must file?

Are you an ALE (Applicable Large Employer)?A company with over 50 full-time equivalents

Multiple Entities – Each is NOT treated separately if there is common ownership

Measurement Period/Lookback Period

Who to cover as full-time?Any employee who works on average, 30+ hours per week

1094/1095 B vs 1094/1095 C

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• Individual Mandate Penalty reduced to $0.00 for tax year 2019

• Individuals no longer face monetary penalty for not having insurance

• But even with zeroing of penalty, the IRS will not process individual tax returns for tax year 2019 unless taxpayers indicate whether they have health coverage

• 2019 will be the second year the IRS will not accept or process tax returns that omit health insurance information

• Electronic returns omitting the information will not be accepted; paper forms processing will be delayed

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1095-C or 1095-B Participant Statements

Postmarked to employees by March 2nd 2020

1094-C or 1094-B Employer Statements

March 31, 2020(electronic filing)

New clients needing ACA Compliance

Notify us you need reporting by December 1st, 2019

Approving your ACA Forms Must be approved by February 4, 2020 (extended from previous January 4 deadline)

IRS DEADLINES

DP DEADLINES

2019 ACA Reporting Deadlines

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How we DO want you to feel

this year…

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So… what can I do now?audit, audit, audit!

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ü V E R I F Y E M P LOY M E N T C AT E G O R I E S

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So… what can I do now? Step 1

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ü V E R I F Y M E D I C A L S TA R T & S TO P D AT E S

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So… what can I do now? Step 2

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Click to edit Master title style

ü V E R I F Y H I R E , R E H I R E , & T E R M I N AT I O N D AT E S

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So… what can I do now? Step 3

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ü V E R I F Y A L L D E P E N D E N T S A R E I N I S O LV E D

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So… what can I do now? Additional Step

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Reminder:Approve forms “push button” by January 4th, 2020

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Common Mistakes

Line 16 is blank for just one single month

The benefit plan for this employee did not start on the 1st of the

month or did not end on the last day of the month.

Double check on the employment status of the EE!

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A known FT EE is not generating a form

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Common Mistakes

Line 15 has a number on it

You offered MEC and MV coverage, but it was NOT

affordable.

Only populates if lowest cost monthly amount offered is above a certain

percentage of the Federal Poverty Line (FPL) as established by the IRS. Both the

percentage and the Federal Poverty Line amount change from year to year.

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Code 1E is showing on line 14, but no codes show up on line 16

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PLEASE NOTE: If you have an employee who is inactive at any point in the year, you MUST go review their forms. iSolved may pull the wrong codes depending on how you handled

the enrollments while they were inactive. Please be sure to review these employees.

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How will employers be notified if they are responsible for paying a penalty?

This will be done through a letter called “Letter 226J” which will include all of the details about what penalties you will be responsible for paying.

What will be included in the IRS letter?

These letters will also include a Form 14765 which will outline in detail the months that employees received tax credits for reduced health premiums from the exchange and will therefore mean the employer is subject to a shared responsibility payment/penalty

Employers will have 30 days to respond with Form 14764- ESRP Response and should setup internal / external resources for a timely review and response

Consult with your benefits broker and tax, legal support resources. (you may request a 30 day extension to prepare your response)

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Penalties

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What We Are Doing to Prepare for 2019 Compliance

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Setup 2019 Reporting Year, update measurement periods to enable client Previews of ACA reporting and forms

2019 ACA Processing support - communication tracking ticket will be used for ACA clients with IRS Instructions for 2019 Preparation Guide

Proactive review to identify employers who grew to 50 Full-Time Equivalents in 2018 and may now be required to file for 2019 (if you are unsure, let us know and we will run the Applicable Large Employer [ALE] test report for you)

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2019 ACA Preparation Guide and Checklist: Available online for downloading

2019 ACA –Zendesk Tracking Ticket Updates

2019 IRS Instructions for Forms 1094-C and 1095-C

ACA 2019 Preparation Guide

ACA 2019 Checklist

Preview 2019 ACA Forms: You can start previewing forms today

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Next Steps & Helpful Tools

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The Future of ACATwo new rule changes:

• Short-Term, Limited Duration Insurance (STLDI)• Expands insurance plan selection• Instead of being uninsured, lets consumers have the option to

either pay ACA plan premiums or buy into the STLDI market

• HRA Expansion• Effective Jan. 1, 2020, two new types of Heath Reimbursement

Arrangements (HRAs) available to employers• Individual Health Coverage HRA (ICHRA)• Excepted Benefit HRA (EBHRA)

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6 States have approved the individual mandate on the state levelCA, DC, MA, NJ, RI, VT

Statewide Individual MandatesBenefits

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üDeadlines• By Dec 1st: New clients notify DP that they need ACA Reporting• By Feb 4th: Clients must approve 2019 ACA forms in iSolved• By March 2nd : Clients distribute 1095 forms to employees• By March 31st: DP to electronically file 1094 & 1095 forms with

IRS

ü Review updated IRS 2019 instructions

ü Verify that accurate employee data is in iSolved

ü Watch for 2019 ACA – Zendesk ticket for updates and reminders

Main Take-AwaysBenefits

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Questions? Contact Us!

benefits@dominionpayroll.com

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Questions?