Three important deadlines are approaching for certain aspects of the Patient Protection and Affordable Care Act (PPACA), also known as the Affordable Care Act (ACA). The following
\narticle discusses these 3 deadlines, whom they apply to, and the necessary forms and reporting information
\nemployers will need.<\/p>\n
There are 3 main components or pieces to health-care reform: 1) the individual mandate; 2) the employer-shared responsibility provisions—also called the play-or-pay rules; and 3)
\nthe health-care exchanges or marketplaces.<\/p>\n
The individual mandate requires most people to have health coverage or pay a penalty. The employer-shared responsibility or play-or-pay rules require large employers to offer full-time
\nemployees quality\/affordable health coverage or pay a penalty. The health-care exchanges or marketplaces
\nare where people can go to get health coverage. Individuals may, depending on their household income, be eligible for government subsidies to help pay for their health coverage through
\nthe exchanges or marketplaces.<\/p>\n
Sections 6055 and 6056 of the Internal Revenue Code obligate most employers to provide certain information to the government and the employees. The government will use the information
\nto determine which individuals are eligible for subsidies under the exchanges or marketplaces and whether
\nthe employer owes a penalty under the employer-shared responsibility provision or play-or-pay rules. The employees will use the information when they complete their personal tax returns
\n(i.e., Form 1040s). <\/p>\n
The Internal Revenue Service (IRS) has released, in draft format, the forms (with the accompanying instructions) that employers have to complete to comply with these reporting
\nrequirements. There are 4 forms. The employer’s size and whether the employer’s group health plan is insured or
\nself-funded dictate which forms and what sections of the forms the employer has to complete. <\/p>\n
Employers may, but are not required to, report data for 2014. If they choose to report this information, it will be due early in 2015. It is doubtful that many employers will report
\n2014 information. Employers must, however, start gathering the information beginning January 1, 2015, and will
\nhave to submit the forms to the IRS and provide the information to the employees early in 2016. The following is a brief summary of the rules.<\/p>\n
If the employer has fewer than 50 full-time (i.e., employees working 30 hours or more per week) and full-time equivalent employees, and the employer sponsors a fully insured health
\nplan, the employer need not prepare and file any reports with the IRS or distribute anything to the employees.\n<\/p>\n
If the employer has fewer than 50 full-time (i.e., employees working 30 hours or more per week) and full-time equivalent employees, but sponsors a self-funded health plan, then the
\nemployer has to complete IRS Forms 1094-B and 1095-B, submit both forms to the IRS, and provide a copy of Form
\n1095-B to the employees.<\/p>\n
If the employer has at least 50 full-time (i.e., employees working 30 hours or more per week) and full-time equivalent employees, and sponsors a fully insured health plan, the employer
\nhas to complete only the top 2 parts of IRS Forms 1094-C plus Form 1095-C, submit both forms to the IRS,
\nand provide the employees with a copy of Form 1095-C.<\/p>\n
If the employer has at least 50 full-time (i.e., employees working 30 hours or more per week) and full-time equivalent employees, and sponsors a self-funded health plan, the employer
\nhas to complete all 3 parts of IRS Forms 1094-C plus Form 1095-C, submit both forms to the IRS, and provide
\nthe employees a copy of Form 1095-C.<\/p>\n
Following are the links to drafts of the 4 forms and the instructions. It is important to determine which forms you have to complete and begin gathering the data starting January 1,
\n2015.<\/p>\n
There are special transitional rules that provide simplified reporting methods for the 2015 calendar year. However, now is the time to start preparing for the reporting requirements.\n<\/p>\n
To help streamline the U.S. health system, which can be complicated, group health plans will have to obtain and use a health-plan identifier, or HPID. The HPID is a uniform
\nidentification number health plans will use to receive and transmit data. If the employer sponsors a fully-insured
\nhealth plan, the insurance carrier will get the HPID. However, if the employer sponsors a self-funded health plan, the employer will have to get the HPID. <\/p>\n
If the self-funded health plan is considered a large plan, the due date to register and get the HPID is November 5, 2014. The due date for a small self-funded health plan is November
\n5, 2015. A self-funded health plan is considered large for these purposes if the self-funded health plan paid
\nat least $5 million in claims during the previous calendar year.<\/p>\n
The following is the government’s website devoted to getting the HPID. This site contains educational material including videos on how to get the HPID.<\/p>\n