Update on the ACA and Other Regulatory Developments

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1 Update on the ACA and Other Regulatory Developments Andrew Malahowski February 9, GALLAGHER BENEFIT SERVICES, INC GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS Agenda IRS reporting under Code Sections 6055/6056 and extensions of deadlines New affordability guidance New employer shared responsibility penalty amounts for 2016 PACE Act change to the definition of small employer Repeal of the automatic enrollment requirements of PPACA Cadillac Plan Excise Tax and its delay until 2020 Recent regulatory guidance concerning coverage of same-sex spouses 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 2 1

2 Sections 6055 and 6056 Reporting 2015 GALLAGHER BENEFIT SERVICES, INC GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 3 Sections 6055 and 6056 Reporting If your organization was an ALE in 2015, it is subject to Section 6056 reporting You must complete a Form 1095-C (Parts I and II) for each FT employee employed by you during any month of the calendar year Remember, the ACA definition of FT applies! Distribute Forms 1095-C to FT employees by January 31 March 31 and submit to the IRS (along with transmittal form 1094-C) by February 28 May 31 (March 31 June 30 if e-filing) 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 4 2

3 Sections 6055 and 6056 Reporting If your organization sponsored a self-insured group health plan in 2015, it is subject to Section 6055 reporting If you are an ALE, you must complete Form a 1095-C Part III (for employees) or 1095-B (for other responsible individuals )* enrolled in coverage during the calendar year If you are not an ALE, you must complete a Form 1095-B for each responsible individual enrolled in coverage during the calendar year Distribute Forms 1095-C/1095-B to FT responsible individuals by January 31 March 31 and submit to the IRS (along with transmittal form 1094-C/1094-B) by February 28 May 31 (March 31 June 30 if e-filing) 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 5 Form 1095-B: Parts I, II, and III 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 6 3

4 Form 1095-B: Part IV 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 7 Form 1094-B 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 8 4

5 Form 1095-C: Parts I and II 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 9 Form 1095-C: Part III 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 10 5

6 Form 1094-C: Part I 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 11 Form 1094-C: Part II 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 12 6

7 Form 1094-C: Part III 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 13 Form 1094-C: Part IV 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 14 7

8 New Affordability Guidance 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 15 New Affordability Guidance A brief refresher on affordability: Coverage is affordable if the employee s contribution for the lowest cost, minimum value, self-only coverage does not exceed 9.66% of the employee s household income Employers measure affordability using one of three safe harbors Federal poverty line; rate of pay; W-2 The 2014 IRS regulations state 9.5% as the applicable percentage 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 16 8

9 New Affordability Guidance IRS Expands Inflation-Adjusted Percentage to Safe Harbor In Notice , the IRS finally synced up the regulatory safe harbor percentage with the inflation-adjusted percentage Therefore, 9.66% is the 2016 safe harbor percentage The safe harbor will track the indexed amount in future years The 2015 amount is 9.56%, and that amount can be used for reporting purposes 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 17 New Affordability Guidance Opt-out Payments The IRS will require employers to include the opt-out payment amount in the employee s contribution towards the cost of coverage, for purposes of determining affordability For plan years beginning before January 1, 2017, transition relief is available for opt-out arrangements that were already in effect, adopted, or communicated before December 16, 2015 Example: Employee pre-tax salary reduction contribution = $90 per month Cash opt-out incentive = $50 per month Employee contribution for affordability purposes = $140 per month 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 18 9

10 New Affordability Guidance Flex Credits / Defined Contribution Flex credits, or a defined contribution, might be provided to employees to pay for employer-provided health and welfare benefits (such as health, dental, vision, FSA, disability, life, dependent care, etc.) Employers that provide flex credits for their health and welfare benefits will be required to follow three requirements in order for the employer contribution to effectively reduce the total employee contribution when measuring affordability: The credits may be used to pay for minimum essential coverage; The credits cannot be cashed out; and The credits may be used exclusively for medical care expenses (as defined under Code Sec. 213) GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 19 New Affordability Guidance Flex Credits / Defined Contribution For plan years beginning before January 1, 2017, transition relief applies to flex credit arrangements that were already in effect, adopted, or communicated before December 16, 2015 Example: Cost of single coverage = $140 per month Employer defined contribution = $50 per month *Assume this defined contribution can pay for non-medical benefits Employee contribution for affordability purposes = $140 per month 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 20 10

11 Employer Shared Responsibility Penalties 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 21 Employer Shared Responsibility Penalties 4980H(a) penalty ALEs that do not offer minimum essential coverage to substantially all (95%) of their full-time employees and their dependent children will be subject to a significant penalty if just one full-time employee is eligible for a premium tax credit and enrolls for health coverage through a Marketplace Headcount penalty multiplied by number of full-time employees (but first 30 are free ) 2014: $2, : $2, : $2, GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 22 11

12 Employer Shared Responsibility Penalties 4980H(b) penalty ALEs that fail to offer affordable, minimum value coverage to *any* full-time employee may have penalty exposure for a different penalty Individualized penalty for each full-time employee who elects coverage under the Marketplace and receives premium tax assistance 2014: $3, : $3, : $3, GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 23 PACE Act Definition of Small Employer 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 24 12

13 PACE Act Definition of Small Employer Under PPACA, small employers with fully-insured group health plans are required to (among other things) offer essential health benefits, and are governed by community rating rules Large employers are not governed by these rules Last October, President Obama signed the Protecting Affordable Coverage for Employees ( PACE ) Act into law Prior to the PACE Act becoming law, the definition of small employer was set to expand under PPACA to include employers with 100 or fewer employees beginning in GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 25 PACE Act Definition of Small Employer The PACE Act makes this expansion voluntary for states, which may now continue with a small employer definition that is based on 50 or fewer employees instead Most states will continue to define a small employer as one with 50 or fewer employees This is now permitted by the PACE Act Some states already passed legislation to expand the definition of small employer to include any employer with 100 or fewer employees However, some of these states may revisit this legislation in the future to conform to the more common 50-or-fewer standard 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 26 13

14 Repeal of ACA Automatic Enrollment 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 27 Repeal of ACA Automatic Enrollment Automatic enrollment would have required employers subject to the Fair Labor Standards Act employing more than 200 full-time employees to automatically enroll new full-time employees in a health plan offered by the employer Automatic enrollment would have been subject to any applicable waiting periods, would have included a notice requirement, and would have required that employees be given an opportunity to opt out of the health plan before coverage began or in the future 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 28 14

15 Repeal of ACA Automatic Enrollment The automatic enrollment provision was not expected to become effective until regulations were released Regulations were never released The Bipartisan Budget Act of 2015 removed the automatic enrollment provision of PPACA, so that provision will never become effective 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 29 Cadillac Plan Excise Tax and Delay 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 30 15

16 Cadillac Plan Excise Tax and Delay The Cadillac Plan Excise Tax was enacted as part of PPACA The tax applies to the cost of employer-sponsored health coverage that exceeds certain threshold limits $10,200 for self-only coverage and $27,500 for family coverage increased each year after the effective date The excise tax was scheduled to become effective on January 1, GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 31 Cadillac Plan Excise Tax and Delay As part of an omnibus bill passed and signed in December, the Cadillac Plan Excise Tax is delayed until January 1, 2020 In addition to delaying its effective date, the omnibus bill will make all taxes paid by employers pursuant to the provisions of the Cadillac Plan Tax deductible for tax purposes The omnibus bill requires the commission of a study by the U.S. Government Accountability Office to look into adjusting the Cadillac Plan Tax threshold to reflect the age and gender of the insured 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 32 16

17 Same-Sex Marriage 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 33 Same-Sex Marriage Following the U.S. Supreme Court s 2013 decision in Windsor, same-sex spouses may receive the same tax-favored health benefits (among other things) as opposite sex spouses Following the Court s 2015 decision in Obergefell, states must issue same-sex marriage licenses and must recognize same-sex marriage As a practical matter, fully-insured plans offering coverage to opposite sex spouses must also offer coverage to same-sex spouses Self-insured plans are not commanded by ERISA to cover same-sex spouses, but self-insured plan sponsors that fail to do so may face legal risk under Title VII of the Civil Rights Act of GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 34 17

18 Same-Sex Marriage The IRS issued Notice , which provided additional guidance that you may have missed If employers chose to allow same-sex spouses onto the plan and allowed those changes mid-year on a pre-tax basis, an employer s cafeteria plan must contain the significant improvement of coverage mid-year election change If an employer s cafeteria plan does not currently allow this mid-year election change, the employer may retroactively amend its cafeteria plan if the amendment is approved by the IRS deadline (December 31, 2015 for calendar-year plans) NOTE: If an employer permitted employees to add same-sex spouses to whom they married after the Obergefell decision was released, such additions would actually be HIPAA special enrollments and would be permissible election changes on grounds other than a significant improvement in coverage 2016 GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 35 Andrew Malahowski joined Gallagher Benefit Services, Inc. in 2014, after twelve years in private practice in employee benefits law and employment law. Andrew was previously a partner and shareholder with an employment and benefits boutique law firm in Chicago, Illinois, where he represented both public and private sector employers in a broad range of employee benefits matters. His counseling experience includes the design, administration, and drafting of employee benefit plans, and he has counseled clients with respect to compliance obligations under ERISA, PPACA, COBRA, HIPAA, and various other employee benefits laws and regulations. Andrew is a graduate of the University of Notre Dame, cum laude, and the University of Notre Dame Law School, magna cum laude. He is a licensed attorney in the States of Illinois and Texas GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 36 18

19 The intent of this presentation is to provide you with general information regarding te status of, and/or potential concerns related to, your current employee benefits issue. It does not necessarily fully address all your specific issues. It should not be construed as, nor is it intended to provide, legal or tax advice. Questions regarding specific issues should be addressed by the your organization's general counsel, tax advisor, or an attorney who specializes 2015 GALLAGHERin BENEFIT this SERVICES, practice INC. area GALLAGHER BENEFIT SERVICES, INC. ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS 37 19

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