Prepare for 2016 ACA deadlines
Employers should prepare for the reporting requirements mandated by the Affordable Care Act even though the deadline to file has been pushed to 2016, say employee benefit experts.
Businesses need to determine which forms are required by the Internal Revenue Service and whether the employer, plan sponsor or insurer will file them, says Christine Williams, an employee benefits attorney with Seattle-based Perkins Coie LLP, who last week led a webinar hosted by the Nevada Business Group on Health for more than 100 of its members and other area human resources professionals.
The forms are not due until early February and March, 2016, but Williams said employers should work on systems now to gather the data, which may be spread across the business in different formats, and make it readily available.
The forms include a minimum essential coverage report, which demonstrates an employer is providing the baseline insurance outlined by the law and must be filed by self-insured employers with fewer than 50 fulltime employees and multiemployer plans.
Forms for shared responsibility – the so-called pay or play clause that requires larger employers to offer insurance or pay or a penalty – must be filed by employers with 50 or more fulltime employees regardless of whether the business offers insurance.
Williams says there are some things employers should be aware of and watch out for.
To avoid pay or play penalties, for example, employers should be certain to demonstrate that they offer insurance with “substantial hospital and physician services,” not so-called skinny plans and that the portion paid for by an employee is affordable.
Williams says that form, unlike other IRS forms, requires both dollars and cents.
“The IRS usually wants rounding,” says Williams. “And what that says to me is the IRS is going to be very rigorous on affordability.”
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