Smart Benefits: Large Employers Need to Report in 2015 Under ACA

Amy Gallagher, GoLocalProv Business/Health Expert

Smart Benefits: Large Employers Need to Report in 2015 Under ACA

On March 5, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final rules for insurer and employer reporting requirements that will be due starting in 2015. Only employers with more than 50 employees will be subject to the requirements since they are the ones subject to the “pay or play” penalties that stem from the Affordable Care Act.

The key reporting provisions are as follows:

A single, combined form for information reporting.

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  • Employers that self-insure will have a streamlined way to report under the employer and insurer requirements thanks to a consolidated form used to report under both sections 6055 and 6056. The top half of the form will address information needs for section 6056 and the bottom half 6055 requirements.
  • Large, fully insured employers will complete only the top section of the form for 6056. Insurers will report only under section 6055, separately. Insurers will not have to report for those who enroll in the state insurance exchanges, who will report that enrollment.

Simplified Option for Employers. Employers who provide a “qualifying health plan” to any of their full-time employees will be given a simplified alternative to the monthly reporting requirement. If the qualifying plan provides minimum value coverage and doesn’t cost the employee more than 9.5% of the federal poverty level (approximately $1,100 annually) toward the cost of an individual plan, employers will only need to report names, addresses and taxpayer ID numbers, along with the fact that they are receiving qualified health plans for all twelve months of the year.

If the employer offers a qualifying plan for less than 12 months, employers will still be able to use the simplified reporting, but will need to use a code on the form indicating that a qualified plan was offered.

To phase in this option, employers who certify that they are offering qualified coverage to at least 95% of their full-time employees (plus an offer to families) will be able to use even simpler reporting for 2015. These employers will be able to use the method for the entire workforce, even those who do not receive a qualifying offer for the full year. Employers will need to supply these employees with standard notices that state the employer attempted to offer the qualified coverage, and their possibility of earning premium tax credits if they are eligible for the exchanges in the state where they reside. Employers will also be given the option within the report to identify their full-time employees who are working 30 or more hours as long as they certify they are offering coverage to at least 98% of the employees on whom they’re reporting.

More specifically, the following information is required in each section of the report:

For section 6055:

  • Information about the entity providing the coverage, including contact information
  • Identify individuals enrolled in the plan, and the months covered

For section 6056:

  • Information about the employer offering coverage, including contact information and number of employees
  • Identify type of coverage (if applicable) for each employee, by month, including the lowest cost for the self-only coverage

At this time, the streamlined form does not require information about the length of any waiting period for benefits, employers share of the costs, or the amounts of advance payment of the premium tax credit and cost-sharing reductions.

Amy Gallagher has over 21 years of healthcare industry experience guiding employers and employees. As Vice President at Cornerstone Group, she advises large employers on all aspects of healthcare reform, benefit solutions, cost-containment strategies and results-driven wellness programs. Amy speaks regularly on a variety of healthcare-related topics, and is often quoted by national publications on the subject matter. Locally, Amy is a member of SHRM-RI, the Rhode Island Business Group on Health, and the Rhode Island Business Healthcare Advisory Council.

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