Video instructions and help with filling out and completing Who Form 1094 B Entities

Instructions and Help about Who Form 1094 B Entities

Thank you for joining our presentation on information reporting required under the affordable care act with updates for 2016 as well as a case study for reporting examples I am rich Wilbur with Hartman employee benefits just a quick disclaimer of course that this is presentation is intended to be for informational purposes only specific guidance for your own group and your reporting requirements should be given by appropriate counsel I feel free to reach out to us with any questions and we can help you through specifics so the reporting requirement applies in two different ways if you are an applicable large employer or if you are self-funded you will have a reporting requirement I'm going to assume for purposes of the presentation that employers are generally aware if they are considered an applicable large employer this is a Armen under Section 60 56 of the law and it basically allows the IRS to audit your self-reported compliance with the employer mandate the second reporting requirement for self-funded plans not fully insured but if you are self-funded this section 6055 requirement allows the IRS to track minimum essential coverage that is that your employees are enrolled in this isn't really so much an employer requirement as much as it is about an issuer of coverage so as a self-funded plan you are the issuer of minimum essential coverage and all issuers of coverage have to provide this reporting to the IRS in general that's going to come from a fully insured health insurance company but when you are self-insured you become the issuer of that coverage and in the reporting requirement Falls to you so if you are large and fully insured you only have to comply with section 60 56 if you are large and self-insured you have to comply with both 16:56 in 1655 and if you are small and self-insured only the 6055 requirement applies to you but we'll go through both of those here as an apple large employer again I have a slide in here sort of helping you understand if this applies to you in general I think most groups are familiar with us at this point just one important thing to point out perhaps is make sure you consider employer aggregation under common ownership so if your company has common ownership with another company it's important to explore the relationship of that of that ownership between the two companies to make sure that it is in fact two separate companies as opposed to one combined aggregated large employer so if there are questions on that that's a more specific review so as a cell if you have a self-funded plan oftentimes we get questions from employers saying well does this apply to my HRA technically my HRA is a self-funded plan in the IRS kind of went back and forth on guidance on this last year but the inclusion was as long as your HRA is integrated with a health plan from the same plan sponsor there is no separate reporting requirement here so if you as the employer and plan sponsor provide a health plan with an HRA that is integrated with that health plan and everyone who's enrolled in the HRA is also enrolled in your health plan then you have no reporting requirement however you could have a scenario where you're offering an HRA that integrates with perhaps a health plan of a spouse's employer that is permissible and in that case you are integrating your HRA with a health plan of a different plan sponsor and inmate and you would have a separate reporting requirement now for your HRA but in general the most common application HRAs do not need to be reported but the reporting requirement does apply to self-funded minimum essential coverage in which includes skinny plans you might be offering a a self-funded plan that essentially only covers preventive services is a minimum essential coverage plan and even though the benefits are extremely limited it would still require reporting the reporting process and timeline is the big thing that was updated for 2016 what you will see here is the original process in timeline that was written into the rules but in 2015 reporting which was completed in early 2016 calendar year the 2015 reporting had some across-the-board extensions and that have been removed so for 2016 reporting to be completed in early 2017 the employer be required to provide a statement form 1095-c presumably to an employee by January 31st you can deliver this to the employee in any manner permissible for delivering w-2s however if you're intending to distribute them electronically I would encourage you to take real specific look at the instruction set for this as in addition to getting a consent to distribute electronically you have to get that consent confirmed electronically by the employee that's a it's a bit of a process so in general I recommend mailing mailing the statement if you get the forms to the employee by January 31st you are then obligated to file a copy of those forms along with the transmittal the 1094 form the cover sheet off to the IRS by February 28th if you're filing on paper which is permissible if you're filing fewer than 250 returns if you're filing electronically which is mandatory if you're filing more than 250 returns you have until March 31st to complete that electronic filing there are some extensions and waivers here in a process for that I won't go through that in extreme detail the intent of the presentation is to hopefully get everybody prepared to do this within the normal timeline there are penalties for failing to report or providing inaccurate information those penalties last year were were generally waived where the IRS put out language saying if the employer shows a good fake effort there would not be any penalties for non-compliance or incomplete information that that language has gone way so