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Payroll Today

Plan now for ACA compliance in 2017

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Alice Gilman

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in Payroll Today

It’s almost Labor Day, which means that it’s time to determine what went right and what went wrong with your Affordable Care Act compliance efforts this year.

Were all of your full-time employees offered affordable group health benefits that provided minimum coverage? Did your full-time employees receive their 2015 Forms 1095-C on time? Were they correct?

Welcome, autumn

September and October are crucial months for calendar year group health plans that use a one-year lookback/stability safe-harbor method to determine whether employees worked full time.

September should be the last month of the lookback portion of the safe harbor that spanned 2015 and 2016; October should begin the 90-day administrative period, and also the next standard measurement period for the next year’s determination. Hopefully, the administrative period coincides with your open enrollment period.

While you are setting up your lookback period for 2017, be sure to include new, variable-hour employees who have made it through their initial measurement periods and who are now considered current employees.

Employees who didn’t work full time during the lookback period don’t have to be offered group benefits for 2017, although you may offer them benefits, if you choose. If you choose not to offer part-time employees benefits next year, you need to communicate this information carefully, because no one likes to hear that they’re losing their health benefits.

Idea: Tell employees that, in compliance with the law, you’re not offering them health benefits in 2017.

Information reporting

Employers with insured plans must provide full-time employees with their copies of Form 1095-C by Jan. 31, 2017. Employers with self-insured plans must provide any employee who enrolls in coverage, including part-time employees, with their copies of Form 1095-C by Jan. 31, 2017.

Paper forms are due to the IRS on Feb. 28; e-filed forms are due on March 31.

Ensure that you have the following information, so employees’ forms are correct:

  • The type of coverage offered, for Line 14 reporting
  • The monthly premium for lowest-cost self-only coverage, for Line 15 reporting
  • Your affordability safe harbor, for Line 16 reporting
  • The Social Security numbers of employees’ dependents, for Part III reporting by self-insured group plans. Idea: Modify your open enrollment forms now to capture this information.

Form 1094-C is the transmittal for Form 1095-C. You’ll need the following information to complete it correctly:

  • The number of months during which you offered minimum essential coverage (all 12 months or the exact months)
  • The total number of full-time employees each month
  • The total number of full-time and part-time employees each month.

{ 1 comment… read it below or add one }

Alfred Anderson September 14, 2016 at 3:29 pm

Thanks for the information. It has been difficult for us to keep up with all of the compliance changes. We resorted to hiring another person primarily for all of the ACA tracking and working with a third party (boomtax) to handle our e-filing and 1095-C distribution. We weren’t able to get everything filed in time so a am sure we will be seeing a few penalties heading our way. I understand the idea and need for the ACA, but our bottom line is feeling it more than anyone.


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