MERCER MARKETPLACE. Health Care Reform Reporting Webcast. 30 April 2015

Transcription

1 MERCER MARKETPLACE Health Care Reform Reporting Webcast 30 April 2015 Judy Bauserman Washington, DC Mike McDonald Dallas, TX Wade Symons Portland, OR

2 TODAY S SPEAKERS Judy Bauserman Washington, DC Mike McDonald Dallas, TX Wade Symons Portland, OR 1

3 Agenda Section 1: Employer Shared Responsibility Section 2: Health Care Reform Reporting Section 3: Client Considerations Section 4: Health Care Reform Reporting Support Package Section 5: Next Steps Section 6: Frequently Asked Questions & Contacts Appendix A: Data Requirements Overview 2

4 Section 1 MERCER MARKETPLACE Employer Shared Responsibility 3

5 Employer Shared Responsibility Requirements in 2015 Offers of Coverage Large employers must offer minimum essential coverage (MEC) to substantially all full-time employees and dependent children (to end of month of age 26) Or face a ($2,080 x # of FTEs) payment if at least one full-time employee obtains subsidized coverage in the public exchange Health Plan Standards If an employer offers coverage that does not provide 60% minimum value or affordable contributions (>9.5% of employer safe harbor) AND A full-time employee obtains subsidized coverage in the public exchange STOP! Definitive prospective determinations of offers of coverage to substantially all cannot be made as populations can shift The employer will be subject to a $3,120 payment Offering employers are also subject to $3,120 payment for any full-time employee not offered MEC who obtains subsidized coverage in the public exchange 4

6 Employer Shared Responsibility How The Payment Will Work In Did you average 100 or more full-time and full-time equivalent employees in 2014? (Aggregate controlled group members) Yes No You will not be subject to a shared responsibility payment but those with 50+ are still subject to ESR reporting for Do you offer a health plan to substantially all (70%) full-time employees (FTEs) and their dependent children (not spouses/domestic partners)? (Disaggregate controlled group members) Yes 3. Does the health plan offered to FTEs satisfy standards for both: (1) affordability (employee-only contribution for plan 9.5% of an employer affordability safe harbor or 9.56% of employee s household income), and (2) minimum value (60%)? Yes 4. Do you have any FTEs to whom you do not offer a health plan? No You will not be subject to a shared responsibility payment. No No Yes You will pay: $2,080* x (total # FTEs first 80 FTEs) Applies if at least one FTE receives taxsubsidized benefits for exchange coverage $2,080 Non-offering Employer Payment You will pay the lesser of: $3,120* x FTEs receiving tax-subsidized benefits for exchange coverage or $2,080* x (total # FTEs first 80 FTEs) $3,120 Offering Employer Payment Notes Box 1: Employers must meet certain rules to use 100 (vs. 50) count for Beginning in 2016, count drops to 50. Every large employer with 50 or more full-time or equivalent employees must begin ESR reporting for 2015 coverage (no exception for employers with 50-99). Box 2: Beginning in 2016, the percentage increases to 95%. Non-offering employer payment: Beginning in 2016, the total number of FTEs will be reduced by 30, not 80. * Mercer estimate based on 2015 HHS inflation adjustment. Payments will increase annually to reflect the projected average national increase in health insurance premiums. 5

7 Employer Shared Responsibility How Do You Identify Full-time Employees? ACA definition What is a full-time employee? Employee averaging at least 30 hours of service per week 130 or more hours of service per calendar month Employer s eligibility definition may or may not match the 30-hour rule Requirement Employers must identify and report all FT employees (based on ACA/ESR definition and measuring methods) Exception Special 98% offer rule 6

8 How Do You Measure 30 Hours? Monthly Method Employers determine whether an employee is a full-time employee in real time. Count hours of service each month Employee averaging 30 hours per week or totaling 130 hours is a full-time employee for that month. Some flexibility for employers who want to measure hours of service on a weekly basis: hours for four-week month hours for five-week month Some relief from employer shared responsibility payments during an initial waiting period 7

9 How Do You Measure 30 Hours? Look-back Method Employer determines a standard measurement period (3 to 12 months) to look back at actual service hours Employees determined to work 30+ hours per week over measurement period are full time Hours measured determines full-time/part-time status in a stability period generally same length as measurement period Exception: if measurement period < 6 months, stability period must be at least 6 months for employees measuring full time Employer can use an administrative period (up to 90 days) between the standard measurement period and stability period Employer may also use an initial measurement period for new employees properly classified as variable hour, part-time or seasonal employees - Additional rules apply to initial measurement period - New full-time hires are measured monthly until the first Standard Measurement Period beginning after hire date 8

10 Employer Shared Responsibility Look-back Method Example Ongoing Employee and Calendar-year Plan Ongoing Employee Timeline CYCLE 1 Standard Measurement Period 1 12 month look-back to determine 30+ hrs/week average Admin. Period 1 Timed with OE Stability Period 1 Same length as measurement period 1 (12 months) Oct. 15 Oct. 15 Jan.1 Oct. 15 Jan. 1 Jan. 1 CYCLE 2 Standard Measurement Period 2 12 month look-back to determine 30+ hrs/week average Admin. Period 2 Stability Period 2 Timeline represents Standard Measurement and Administrative Periods coordinated with OE 9

11 Employer Shared Responsibility What Hours Count toward 30 hours average? Paid hours actually worked All paid-time off Vacation Holiday Illness Layoff Jury duty Military duty Or other LOA including disability Special rules for unpaid leaves FMLA Military leave Jury duty Counting Hours Hourly - Count actual hours of service - This is required for hourly Salaried/Exempt - Days-worked equivalency - 8 hours - Weeks-worked equivalency - 40 hours 10

12 Employer Shared Responsibility Interns and Other Limited Duration Employees New FT Non Seasonal Employees Reasonably expected to work full-time, must be offered the ability to enroll by the beginning of the fourth calendar month of employment New Variable Hour or Seasonal Employees Variable Hour - If it cannot be determined that the employee is reasonably expected to work 30 hours per week, employer may apply initial measurement/stability period to employee and not offer coverage until employee meets full-time average Seasonal those in positions for which the customary annual employment is six months or less and who commence working at approximately the same time each year can be considered seasonal - initial measurement/stability period may be applied Employees working for a limited duration cannot automatically be considered seasonal or variable hour employees STOP! Non-seasonal full-time employees who are not offered coverage will be factored into assessment calculations beginning in

13 Look-back Method Example New Variable-hour Employee And Calendar-year Plan Look-back Method Transition from New Variable Hour to Ongoing Employee Timeline Employee s Initial CYCLE New EE Hire Date Admin. Period Employee s Initial Measurement Period Admin. Period Initial Stability Period Feb. 15 Mar. 1 Oct. 15 Mar. 1 Apr. 1 Apr. 1 Oct. 15 Jan. 1 Dec. 31 Employer s Standard CYCLE Begin measuring employee s hours with first standard measurement period occurring after his start date. Standard Measurement Period Admin. Period Standard Stability Period Timeline shows initial and first standard measurement, administrative and stability periods. 12

14 How Do You Determine Minimum Plan Value? Minimum Value Under the ACA, employers at risk for assessments unless they offer at least one plan that pays 60% of covered costs on average The percentage is calculated using the anticipated cost of essential health benefits covered by the plan based on the plan s cost sharing provisions NEW A plan must provide substantial coverage for inpatient hospitalization services and physician services to be considered minimum value Approach for determining minimum value: HHS minimum value calculator STOP! Actuarial value: Minimum Value and Actuarial Value are not the same Portion of claims that are paid by the plan not the member May be used in a number of different ways, including budgeting and expected financial impact of employer plan design changes While appropriate for budgeting purposes and expected financial impact of employer plan design changes, Mercer s MedPrice calculated actuarial values should not be construed as an Affordable Care Act 60% minimum value determination or protection from an IRS employer shared responsibility assessment Actuarial certification for nonstandard plan designs 13

15 How Do You Determine Affordable Contributions in 2015? An employee s required contribution for self-only coverage cannot exceed 9.56% of the employee s household income Safe harbors - contribution less than or equal to 9.5% of: Employee s W-2 wages (Box 1) Hourly rate of pay x 130 hours for hourly employees or monthly salary for salaried employees: - Hourly rate greater than $7.48 will support larger affordable employee contribution than FPL Federal poverty level - $92 per month = $11,670(9.5%)/12. Although individuals affordability percentage is indexed and will be 9.56% in 2015, 9.5% employer safe harbor percentage currently is not indexed. STOP! FPL safe harbor Only safe harbor that can be prospectively determined. Doesn t require individual tracking. Certain simplified shared-responsibility reporting options require use of FPL safe harbor. 14

16 Section 2 MERCER MARKETPLACE Health Care Reform Reporting

17 Health Care Reform Reporting Employer mandate: Did the employer offer the requisite coverage to avoid assessments? Individual mandate: Did the taxpayer have the requisite coverage? Public exchange premium subsidies: Should IRS claw back any premium subsidy taxpayer got last year? May taxpayer claim premium subsidy for any months of last year? The goals stated above are addressed in two sections of the law referenced below Minimum Essential Coverage* ( 6055) Employer Shared Responsibility ( 6056) IRS Filing Include all covered individuals enrolled in MEC Individual Statements to each responsible individual who enrolls self or others in MEC IRS Filing Include each full-time employee Individual Statements to each employee who was full time for at least 1 month during reporting year * No small employer exemption. 16

18 How Large Employers Will Report (MEC and ESR) Self-Insured Employers 1094-C Transmittal Form 1095-C Employee Statement Employer IRS Information Return Employer reports both MEC (6055) and ESR (6056) information on combined forms.* Fully-Insured Employers 1094-B Transmittal Form 1094-C Transmittal Form 1095-B Employee Statement 1095-C Employee Statement Insurer IRS Information Return Employer IRS Information Return Insurer will provide MEC (6055) information on Form 1094-B and 1095-B. Employer will provide ESR (6056) information on Form 1094-C and 1095-C. * Large employers with self-funded plans have the option to use the same forms as insurers Forms 1094-B and 1095-B to report MEC for persons who weren t employees at any time during the reporting year, such as retirees who terminated in previous years or covered non-employee director. Small employers exempt from ESR reporting that have self-funded plans will use 1094-B and 1095-B to report MEC for all enrollees. 17

19 Health Care Reform Reporting Common Features of MEC and ESR Reporting Individual statements plus transmittal form to IRS Combined IRS form may be used Employers sponsoring: Self-funded plans will fill out both MEC and ESR sections Insured plans will fill out only ESR section Must report on calendar year basis even if non-calendar year plan Employees need information to file with tax returns Electronic filing required for employers filing at least 250 returns For employers, these reporting requirements combine benefit and HR data in potentially complex ways STOP! Penalties for non-compliance: $100 for each missed return, up to an annual max of $1,500,000 18

20 2015 Reporting Deadlines The first reports are for the 2015 calendar year Report Paper Electronic 1094-C/1095-C transmittal returns February 29, 2016 March 31, C employee statements February 1, 2016 February 1, 2016* STOP! Have you started collecting the necessary data? *Employers must comply with the IRS conditions for electronic delivery of employee statements. 19

21 Health Care Reform Reporting IRS and Individual Information Reporting Requirements Form 1094-C Form 1095-C Form 1094-C & Form1095-C for MEC (6055) & ESR (6056) Reporting Employers are responsible for the collection, management, and organization of data for IRS reporting purposes as well as the fulfillment of the employee mailings. 20

22 Health Care Reform Reporting Reporting the 1095-C Individual Statement (in brief) Part Part I Part II Information Included Employee and employer identifying information Full-time employee ESR information (by month) Terms of any coverage offered (by code) Lowest employee cost of self-only coverage with minimum value Indicate either enrollment in coverage or various reasons play or pay assessment may not apply (by code) In some cases may be blank Self-funded employer uses special code for non-full-time employee enrolled in MEC Part III MEC reporting (self-funded employer only) Names and TINs of all covered individuals Indicate months with at least one day of coverage for each covered individual 21

23 Health Care Reform Reporting Form 1095-C Participant Statement 22

24 Health Care Reform Reporting Form 1095-C Participant Statement Codes Line 14 1A - MEC providing affordable (based on FPL safe harbor), MV coverage offered to full-time employee, and at least MEC offered to spouse and dependents 1B - MEC providing MV offered to employee only 1C - MEC providing MV offered to employee and at least MEC offered to dependents (not spouse) 1D - MEC providing MV offered to employee and at least MEC offered to spouse (not dependents) 1E - MEC providing MV offered to employee, and at least MEC offered to dependents and spouse 1F - MEC not providing MV offered to employee, employee spouse or dependents, or employee, spouse and dependents 1G - Offer of coverage to an employee not a fulltime employee for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the year. 1H - No offer of coverage (no coverage or offered coverage is not MEC) 1I - Qualified Offer Transition Relief 2015: employee (and spouse or dependents) received no offer; received non-qualifying offer or received qualifying offer for less than 12 months Line 15 Complete only if code 1B, 1C, 1D or 1E is entered in any box on Line 14 Line 16 2A - Employee not employed on any day of the month 2B - Employee is not a full time employee (and did not enroll for the month, if offered) 2C - Employee enrolled in coverage offered 2D - Employee in limited 4980H(b) limited nonassessment period 2E - Multiemployer interim relief rule 2F - Form W-2 safe harbor for affordability 2G - FPL safe harbor for affordability 2H - Rate of pay safe harbor for affordability 2I - Non-calendar year transition relief applies 23

25 Health Care Reform Reporting Reporting the 1094-C Transmittal Form (in brief) Part I Part II Part III Part IV Information Included Employer identifying information for ALE member Number of 1095-Cs submitted with this transmittal form Background ESR and (if self-funded) MEC information Whether this transmittal is authoritative If authoritative, complete Parts II-IV 1. Total number of 1095-Cs for this employer 2. Part of ALE member group (Y/N) 3. Indicate use of simplified offer method or certain 2015 transitional relief Aggregate ESR data (by month) MEC offer to substantially all full-time employees (Y/N) Column (a) Full-time employee count Column (b) All employee count Column (c) Aggregate group member data (if applicable) 24

26 Health Care Reform Reporting Form 1094-C Transmittal 25

27 Health Care Reform Reporting Comparison of Simplified Methods 98% Method Qualifying Offer Method 2015 Qualifying Offer Method Coverage Requirements Minimum value & affordable using rate of pay, W-2 or FPL safe harbor. MEC for dependents (per instructions). Minimum value & affordable using FPL safe harbor (for employees). MEC for spouses & dependents. Minimum value & affordable using FPL safe harbor (for employees). MEC for spouses & dependents. Offer Requirements Minimum offer in all 12 months to at least 98% of employees and dependents for whom Form 1095-C is filed. Don t count employees in limited non-assessment period (LNP) toward 98% if no 1095-C is required (e.g., in LNP for entire year) Minimum value offer to full-time employees with at least MEC offer to spouses and dependents. No minimum percentage. Minimum value offer to 95% of fulltime employees with at least MEC offer to spouses and dependents. Don t count employees in limited nonassessment period toward 95%. Time Period for Relief All 12 months for those for whom employer provides Form 1095-C. Any month during which the employee receives qualifying offer. All 12 months during which the employee is a FT employee and receives qualifying offer. Relief Provided Employer does not have to provide total monthly count of full-time employees. Do not complete Line 15 on 1095-C (lowest cost, self only premium) for employees receiving qualifying offer. Do not complete Line 15 on 1095-C (lowest cost, self-only premium) for ANY FT employee (not just those receiving qualifying offer). Send generic statement ONLY to employees for insured plan and those who didn t enroll in self-funded plan (must have offer for 12 months). Send special generic statement to ONLY to employees for insured plan and those who didn t enroll in self-funded plan (do not need to have offer for all 12 months). Send 1095-C to IRS. Send 1095-C to IRS. 26

28 Health Care Reform Reporting Simplified Reporting Qualifying Offer Method Simplified Statement* Qualifying offer method: For employees offered qualifying coverage for all 12 months.* Qualifying offer method: For employees not offered qualifying coverage for all 12 months 2015 Employer Health Coverage Notice For all 12 months of the calendar year, you and your spouse and dependents, if any, received a Qualifying Offer of health coverage and therefore are not eligible for a premium tax credit. For more information, please contact Lucky Person at (222) ABC Company 555 Any Street City, ST Tax identification number: *Simplified statement not available for employees actually enrolled in self-insured medical coverage. They must receive 1095-Cs. 27

29 Health Care Reform Reporting Simplified Reporting 2015 Qualifying Offer Transition Relief Simplified Statements* Qualifying offer method: For employees offered qualifying coverage for all 12 months Qualifying offer method transition relief: For employees not offered qualifying coverage for all 12 months 2015 Employer Health Coverage Notice For all 12 months of the calendar year, you and your spouse and dependents, if any, received a Qualifying Offer of health coverage and therefore are not eligible for a premium tax credit. For more information, please contact Lucky Person at (222) ABC Company 555 Any Street City, ST Tax identification number: Employer Health Coverage Notice You and your spouse and dependents, if any, may be eligible for a premium tax credit for one or more months of For more information, please contact Luckier Person at (333) XYZ Company 555 Another Street City, ST Tax identification number: *Simplified statement not available for employees actually enrolled in selfinsured medical coverage. They must receive 1095-Cs. 28

30 Health Care Reform Reporting Form 1094-C Transmittal Part III 29

31 General MEC Reporting Forms 1094-B Transmittal And 1095-B Participant Statement 30

32 Health Care Reform Reporting Can Employer Report All Benefit Eligible Employees as Full-time? ESR Reporting 1094-C/1095-C Unless 98% offer method available, appears employer needs to measure hours and determine who is full-time to report Why? Non-offering employer payment ($2,080) avoided by offering MEC to substantially all full-time employees If don t determine who s full time, may not be offering to substantially all STOP! Reporting all as full-time: Over-reporting and/or failing to measure 30-hour employees may create significant risk! 31

33 Section 3 MERCER MARKETPLACE Client Considerations 32

34 Questions Common to All Self-insured Employers and/or Applicable Large Employers What are our third-party vendors doing about this requirement? Where is our data? Employment-based information Benefit-based information For each Applicable Large Employer member Which department will take responsibility for reporting? Payroll? Benefits? HR? Finance? Tax? Legal? Are our plans subject to reporting fully-insured, self-insured, or both? What processes do we need to have in place? Electronic disclosures of employee statements Reasonable efforts to obtain TIN for all covered individuals Should we expand eligibility to qualify for the 98% simplified reporting option? Do we understand the consequences of non-compliance? 33

35 Prepare for a Readiness Review Your local client team will schedule a Readiness Review meeting to focus on: Employer Shared Responsibility (ESR) substantive compliance effective in %/95% rule Identifying/measuring full-time employees Determining affordability Potential assessments Employer Shared Responsibility/Minimum Essential Coverage reporting requirements (2015 calendar year reporting in early 2016) Reporting rationale and deadlines Forms 1094-C / 1095-C and applicable codes Alternative reporting methods 34

36 Section 4 MERCER MARKETPLACE Health Care Reform Reporting Support Package 35

37 36

38 Mercer Marketplace Health Care Reform Support Package Overview One product that provides two solutions Health Care Reform Eligibility & Affordability Eligibility Monthly Measurement Method 30 Hour lookback Determination of eligibility Robust reporting capability Health Plan Affordability Determination Assessment of health plan affordability Affordability utilizing the 3 safe harbors MEC & ESR Reporting Minimum Essential Coverage (6055) and Employer Shared Responsibility (6056) Collect and manage all data required for reporting Provide the employer online access to the data Exportable reporting that meets IRS electronic filing requirements 37

39 Mercer Marketplace Health Care Reform Support Package 30 Hour Eligibility & Affordability Tracking Delivered in conjunction with Equifax Workforce Solutions Calculation of hours worked during the measurement periods Employee eligibility determination based on hours worked during the applicable measurement period Health plan affordable coverage determination Eligibility integration with Mercer Marketplace (eligibility enforcement and employment class update done by Mercer Marketplace) Data Reporting Hours worked by month, employee, and defined employee class Standard trending reports (e.g. monthly eligible and ineligible populations) Annual summary reports 38

40 Mercer Marketplace Health Care Reform Support Package MEC and ESR Reporting Service Collect and manage all data required for MEC (6055) and ESR (6056) reporting Provides the employer online access to the data collected Equifax ACA Compliance Scorecard Reporting Calculates potential ACA penalties Ability to export all required data to complete employee forms (1095-C) Combines and tracks multiple data sources Provides data in.csv file (solution does not populate required forms) Exportable reporting that meets the IRS electronic filing requirements (1094-C) File will be self-service and will be in the prescribed XML version outlined by the IRS Optional Services Available*: Delivered in conjunction with Equifax Workforce Solutions The compiling, fulfillment/printing and mailing of employee 1095-C forms The compiling, fulfilling and electronic posting of employee 1095-C forms Note: Employee consent is also required for this delivery option to be used Ability for customer or delegate to submit the 1094-C form electronically through Equifax s secure interface with IRS (currently pending final IRS e-filing requirements) * Additional fees will apply for set-up, fulfillment and delivery 39

41 Mercer Marketplace Health Care Reform Support Package Pricing Health Care Reform Support Package (Full Solution) Group Size Implementation Fee Annual Subscription Fee Per Employee Annual Minimum Notes: < 5,000 $15,000 $3.90 $10,000 5,001 < 50,000 $22,000 $3.90 N/A 50,000 + $22,000 $3.90 N/A Per employee per year (PEPY) annual subscription is based on TOTAL employees and based on annual monthly average. Equifax will look back at the prior 12 months and take the average number of employees to determine the PEPY Service agreements are 3 years in length Services do not include electronic delivery, printing, fulfillment or postages services of the 1095-C forms. Those services are available for an additional fee If an MMx client has already purchased the Eligibility & Affordability Service and would like to add the Reporting Service, the client will pay the cost of the implementation fee ($12,000) + $3.90 per employee per year they will receive a credit for the previous variable PEPY 40

42 Mercer Marketplace Health Care Reform Support Package Pricing MEC (6055) and ESR (6056) Reporting Add-On (For clients who already have Eligibility & Affordability Services through Equifax) Group Size Implementation Fee Annual Subscription Fee Per Employee Annual Minimum Notes: < 5,000 $12,000 $3.90 $10,000 5,001 < 50,000 $12,000 $3.90 N/A 50,000 + $12,000 $3.90 N/A This service add-on is available to employers who currently have the eligibility and affordability services and wish to add the 1094-C and 1095-C reporting services The implementation fee listed is in addition to the implementation fees billed at the time the eligibility & affordability services were implemented. The new per employee per year (PEPY) annual subscription fee ($3.90) will replace the ongoing per variable employee fee that the employer is being charged for the eligibility and affordability services (see pricing example). The PEPY is based on TOTAL employees and based on annual monthly average. Equifax will look back at the prior 12 months and take the average number of employees to determine the PEPY Service agreements are 3 years in length Services do not include electronic delivery, printing, fulfillment or postages services of the 1095-C forms. Those services are available for an additional fee. 41

43 Mercer Marketplace Health Care Reform Support Package Pricing EXAMPLE NEW Health Care Reform Support Package Customer Health Care Reform Support Package Group Size Implementation Fee Annual Subscription Fee Per Employee Monthly Average Total # of Employees 5,001 < 50,000 $22,000 $ ,000 Year One Implementation Fee $22,000 $22,000 Annual Subscription Fee (PEPY) $3.90 X 20,000 = $78,000 Total Cost (Year 1) $100,000 Years Two and Three Annual Maintenance Fee (PEPY) $3.90 X 20,000 = $78,000 Total Cost (Per Year) $78,000 Assumes average total number of employees remains the same 42

44 Mercer Marketplace Health Care Reform Support Package Other Important Items Additional connection or data consolidation fees may apply from payroll or other third-party vendors STOP! Services must be purchased by June 5, 2015 for 2015 data collection and 2016 filing Implementation and Ongoing fees will appear on the Mercer Marketplace invoice 43

45 Section 5 MERCER MARKETPLACE Next Steps 44

46 Mercer Marketplace Health Care Reform Support Package Next Steps Schedule ACA Readiness Review Schedule Health Care Reform Reporting Support Package Discussion Begin Data Gathering Begin Support Package Implementation At least 12-weeks Any of the following contacts can help you schedule your ACA Review and Support Package Discussion Mercer Marketplace Client Team Lead Service Delivery Specialist Local Relationship Manager April 30,

47 Mercer Marketplace Health Care Reform Support Package Implementation Timeline Project Initiation Determine specific data requirements Review data questionnaire Configuration Build data integration files Review data architecture Build application configuration Data Validation Conduct complete data validation (client & Equifax) Validate and signoff on configuration GO LIVE! Services must be purchased by June 5, 2015 in order to support the 2015 reporting year 46

48 Section 6 MERCER MARKETPLACE FAQs and Contacts 47

49 Mercer Marketplace Health Care Reform Support Package Frequently Asked Questions What alternatives are available if you do not wish to purchase the Mercer Marketplace Health Care Reform Support package? You will be able to run a self-service report from the Benefitfocus platform This report will include data elements that you can supplement to complete the IRS reporting This reporting capability is included with your standard Mercer Marketplace agreement (no additional fees apply). You are responsible for generating the report on the Benefitfocus platform and then using that data to complete the IRS forms, distribute them to participants and file them with IRS When will the report be available? Benefitfocus will be releasing the report functionality in Fall 2015 Can the reports be customized per employer? No the report layout is standard for all Mercer Marketplace clients Is there a Benefitfocus report layout available that can be shared? Yes a sample report will soon be available. Please note that the final file specs/including values are pending legal review and we expect will be finalized by the end of May 48

50 Thank You For Attending Today s Webcast! Please contact your Mercer Marketplace consulting team leader for questions or to receive a proposal for Health Care Reform support services 49

51 Appendix A MERCER MARKETPLACE Data Requirements Overview This chart on the following pages lists required data elements in the draft ESR and MEC reporting forms. Employer means an applicable large employer (ALE) member subject to ESR reporting. Under current guidance, ALE members with self-funded plans will report MEC for employees and nonemployees (such as retirees) on Forms 1094-C and C the same forms used for ESR purposes. Small employers exempt from ESR reporting that have self-funded plans will use the same forms as insurers Forms 1094-B and 1095-B to report MEC. April 30,

52 Data Elements in IRS Play-or-Pay and Minimum Essential Coverage Reporting Forms The charts on the following slides list required data elements in the draft ESR and MEC reporting forms Employer means an applicable large employer (ALE) member subject to ESR reporting ALE members sponsoring self-funded plans can use either Forms 1094-B and 1095-C and 1095-C to report MEC for covered persons who aren t their employees at any time during the reporting year (such as retirees who terminated before the start of the reporting year) and individuals obtaining coverage through such non-employees Small employers exempt from ESR reporting that have self-funded plans will use the same forms as insurers Forms 1094-B and 1095-B to report MEC 51

53 Data Elements in IRS Draft ESR and MEC Reporting Forms Data requirements Form 1094-C to IRS Employer ESR and selffunded plan MEC reporting Form 1095-C to individual and IRS Insurer/other coverage provider MEC reporting Form 1094-B to IRS Form 1095-B to individual and IRS Organization-specific information: Large employer or self-funded plan sponsor identifying and filing information Name, address, employer identification number (EIN) X X Data Source Contact name Contact phone number If governmental entity, identify designated entity (if any) responsible for reporting: Name, address, EIN Contact name Contact phone number X X X X Total number individual statements submitted with transmittal form: Whether this form is authoritative transmittal Total # of individual statements filed with IRS by employer or on its behalf X 52

54 Data Elements in IRS Draft ESR and MEC Reporting Forms Data requirements Form 1094-C to IRS Employer ESR and selffunded plan MEC reporting Form 1095-C to individual and IRS Insurer/other coverage provider MEC reporting Form 1094-B to IRS Form 1095-B to individual and IRS Organization-specific information: Large employer or self-funded plan sponsor identifying and filing information Indicate whether part of a controlled group member; if so, identify: Name and EIN of other controlled-group members (identify up to 30) Certify use of alternative reporting methods or transition relief, if any X X Data Source For each month, give employer s: Total full-time employees (omit if using 98% offers method) Total employees (as of 1st or last day of month) For each month, indicate by code whether employer: Offered MEC Was part of a controlled group Relied on certain transition relief X X 53

55 Data Elements in IRS Draft ESR and MEC Reporting Forms Employer ESR and selffunded plan MEC reporting Insurer/other coverage provider MEC reporting Data Source Data requirements Form 1094-C to IRS Form 1095-C to individual and IRS Form 1094-B to IRS Form 1095-B to individual and IRS Organization-specific information: Insurer/other coverage provider information Name, address, and EIN X X Contact name Contact phone number If employer-sponsored coverage: Employer s name, EIN, and address Total # of individual statements submitted with transmittal form X X X X X Individual data For each employee who was full-time for at least one month during the year: Name, address, and Social Security number (or other TIN) X 54

56 Data elements in IRS draft ESR and MEC reporting forms Data requirements Form 1094-C to IRS Individual data For each month, indicate by code the type of coverage offered (or use checkbox if all 12 months are the same): Minimum-value MEC meeting mainland affordability safe harbor offered employee; MEC offered spouse and dependents (qualifying offer) Minimum-value MEC offered employee only Minimum-value MEC offered employee; MEC offered dependents Minimum-value MEC offered employee; MEC offered spouse Minimum-value MEC offered employee; MEC offered spouse and dependents (Continued on next slide) Employer ESR and selffunded plan MEC reporting Form 1095-C to individual and IRS X Insurer/other coverage provider MEC reporting Form 1094-B to IRS Form 1095-B to individual and IRS Data Source 55

57 Data Elements in IRS Draft ESR and MEC Reporting Forms Data requirements Form 1094-C to IRS Individual data (Continued from previous slide) For each month, indicate by code the type of coverage offered (or use checkbox if all 12 months are the same): MEC lacking minimum value offered (i) employee; (ii) employee and spouse or dependents; or (iii) employee, spouse, and dependents No MEC offered Offer of coverage to enrolled employee who s not FT during any of the 12 months Qualifying offer transition relief for 2015 Employer ESR and selffunded plan MEC reporting Form 1095-C to individual and IRS X Insurer/other coverage provider MEC reporting Form 1094-B to IRS Form 1095-B to individual and IRS Data Source For each month, employee s share of lowest-cost monthly premium for self-only, minimumvalue coverage, if any offered to employee. (Omit to extent using qualifying offers method or if no MV coverage offered) X 56

58 Data Elements in IRS Draft ESR and MEC Reporting Forms Data requirements Form 1094-C to IRS Individual data For each month, indicate by code whether safe harbors or transitional relief limit employer s risk of shared-responsibility assessments related to the employee (enter only 1 code per ordering rule): Applicable affordability safe harbor (rate of pay, W-2, or federal poverty level) Employee not employed during month Employee not full-time Employee enrolled in coverage offered Employee in nonassessment period Multiemployer interim rule relief applies Noncalendar-year plan transition relief applies Employer ESR and selffunded plan MEC reporting Form 1095-C to individual and IRS X Insurer/other coverage provider MEC reporting Form 1094-B to IRS Form 1095-B to individual and IRS Data Source 57

59 Data Elements in IRS Draft ESR and MEC Reporting Forms Employer ESR and selffunded plan MEC reporting Insurer/other coverage provider MEC reporting Data Source Data requirements Form 1094-C to IRS Form 1095-C to individual and IRS Form 1094-B to IRS Form 1095-B to individual and IRS Individual data: Responsible individual information Name, address, and Social Security number (TIN) or date of birth if SSN unavailable Code identifying origin of policy, if applicable SHOP Marketplace identifier, if applicable X* X X X Individual data: Individual coverage information (includes all persons covered by plan) Name and Social Security number (TIN) or date of birth if SSN unavailable X X Months of coverage X X * Nonemployees for entire year, such as covered members of board of directors, reported on Form 1094-B/1095-B by all employers sponsoring self-funded plans. 58

60 Mercer is not engaged in the practice of law and this report, which may include commenting on legal issues or regulations, does not constitute and is not a substitute for legal advice. Accordingly, Mercer recommends that employers secure the advice of competent legal counsel with respect to any legal matters related to this report or otherwise. The information contained in this document and in any attachments is not intended by Mercer to be used, and it cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code or imposed by any legislative body on the taxpayer or plan sponsor. 59

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