Correcting Employer Reporting Errors Needed to Meet Good Faith Compliance Standard

As employers were struggling to complete Forms 1095-C to get them in their employees’ hands by March 31, they had the small comfort that the IRS had announced that employers needed to meet a “good faith compliance” standard to avoid penalties. The expectation was that employers would do their best to comply with this newContinue reading “Correcting Employer Reporting Errors Needed to Meet Good Faith Compliance Standard”

Open Up the Silos for Optimum Compliance

With implementation of the ACA, many brokers and employers have had a laser focus on understanding the requirements necessary to comply with the law. And, rightly so! As such, employers have adopted lookback measurement periods, identified variable hour employees, not to mention a myriad of terms and constructs.  Employers who have filed their 1094-C andContinue reading “Open Up the Silos for Optimum Compliance”

Spring to Sprout Flowers and Appeals!

Flowers may be welcome signs of spring, but a sign that spring is here that may be less welcome is the implementation of the marketplace appeals process for employers. Beginning in 2016, the federally facilitated marketplace (FFM) will send notices to employers if an employee receives APTC and the employee has identified their employer inContinue reading “Spring to Sprout Flowers and Appeals!”

Employer Reporting When Employee Waives Coverage

Many employers are struggling with the ACA’s employer reporting requirements. It’s hard enough to know what to report when an employee enrolls in coverage. But, what is the proper way to report that an employee has waived coverage? Line 16 becomes very important in this scenario. If the employer has adopted an affordability safe harbor,Continue reading “Employer Reporting When Employee Waives Coverage”

Coping with COBRA… and Employer Reporting!

Employer reporting is hard enough! But, employer reporting when there has been a COBRA qualifying event revives images of coiled snakes striking out. Final 2015 instructions for completing forms 1094-C and 1095-C changed some of the rules related to reporting COBRA offers of coverage. Example for Termination at end of month  Facts or Assumptions: EmployerContinue reading “Coping with COBRA… and Employer Reporting!”

Reporting Delay Shouldn’t Cause Consumer Filing Delays

The delay in reporting deadlines announced by the IRS in late December has given many employers much needed breathing room. IRS Notice 2016-4 issued on December 28, 2015 extending the filing deadlines for ACA reporting. Employers subject to the reporting requirements face a deadline of March 31, 2016 to furnish 1095-C statements to each full-timeContinue reading “Reporting Delay Shouldn’t Cause Consumer Filing Delays”

New IRS Notice 2015-87 Announces Increase in Employer Shared Responsibility Penalties

Whatever a broker or employer knows about the ACA is subject to change with little notice. This has been the case since the ACA was enacted into law in 2010. And, the tradition continues with IRS Notice 2015-87. IRS Notice 2015-87 is only 31 pages long. But, many of those pages warrant careful review. OfContinue reading “New IRS Notice 2015-87 Announces Increase in Employer Shared Responsibility Penalties”

ACA Terms and Acronyms Brokers Need to Know

There are a handful of terms and acronyms that relate to the ACA that health insurance brokers need to understand as readily as they understand texting’s LOL! In some respects, the ACA has caused brokers to learn a new language. ALE         Pronounced as each letter – A-L-E or like the beer – ale An ALEContinue reading “ACA Terms and Acronyms Brokers Need to Know”

10 ACA Reporting Reminders and Tips

Small employers with insured health plans do not have to provide reports to their employees or to the IRS. Employers with 50 or more full-time and full-time equivalent employees must report for this year. Transition relief does not apply for reporting purposes. Employers who will file 250 or more information returns must do so electronicallyContinue reading “10 ACA Reporting Reminders and Tips”

Decoding “98 Percent Offer Method” from Line 22 (on Form 1094-C)

Form 1094-C is the transmittal form that is sent to the IRS along with a firm’s Form 1095-Cs. As noted in an earlier blog, this form is far more complicated and confusing than a mere “transmittal form” would suggest. As a reminder, the option on line 22 are: Qualifying Offer Method Qualifying Offer Method TransitionContinue reading “Decoding “98 Percent Offer Method” from Line 22 (on Form 1094-C)”