CUPA - RIO GRANDE CHAPTER ACA (PAST, PRESENT AND FUTURE) Agenda 1. - - PowerPoint PPT Presentation
CUPA - RIO GRANDE CHAPTER ACA (PAST, PRESENT AND FUTURE) Agenda 1. ACA Foundations 2. Past - The Early Days 3. Present - Current State 4. Future Whats Next 5. Solutions ACA Compliance Tools 6. Question and Answer Jeff Taylor
CUPA - RIO GRANDE CHAPTER ACA (PAST, PRESENT AND FUTURE)
1. ACA Foundations 2. Past - The Early Days 3. Present - Current State 4. Future – What’s Next 5. Solutions – ACA Compliance Tools 6. Question and Answer Jeff Taylor Higher Education Specialist Equifax Workforce Solutions jeffrey.taylor@equifax.com 8432573.4147
Individuals must have minimum essential coverage
State and federal exchanges will make subsidies available to individuals. Employers are required to offer coverage to 95%
penalty. The IRS will use forms 1094 and 1095 to enforce the individual and employer mandates.
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Should we pay or play? What exactly is the Affordable Care Act? Do we have to comply with ACA? Let’s just pull reports from our payroll system Is ACA going away? What is 6055 and 6056? 5
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1/14 7/13 Individual mandate goes into effect PPACA signed into law 3/10 Employer mandate delayed 2/14 Final regulations released 11/14 Supreme Court grants judicial review of subsidy cases Employer mandate goes into effect 1/15
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7 Monthly Measurement
determined based on the hours of service for each calendar month
because you don’t know someone is eligible until it is too late Look-back Measurement
future period (stability period) is determined based upon the hours of service in a prior period (measurement period)
2013 2014 2015 2016 J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D SMP 1 SMP 2 SMP 3 Hired 3/15/14 Part-time employee with fluctuating schedule
4/1/14 3/31/15
IMP
4/1/14 3/31/15 31 hours per week 29 hours per week
SMP 2
10/15/14 10/14/15
ISP
5/1/15 4/30/16 Eligible for Coverage 5/1/16 12/31/16 Not Eligible for Coverage
Hired 3/15/14 Part-time employee with fluctuating schedule IMP
4/1/14 3/31/15 28 hours per week 31 hours per week
SMP 2
10/15/14 10/14/15
SSP 2
1/1/16 12/31/16 Eligible for Coverage 5/1/15 12/31/15 Not Eligible for Coverage
A P A P
The final regulations contain numerous rules addressing the treatment of employees who have a change in employment status (e.g., part-time to full-time).
SSP 1 SSP 2
Full-time: reasonably expected to work at least 30 hours per week Variable: unclear at time of hire whether the employee will work at least 30 hours per week Seasonal: hired to work for a period of less than six months Part time: reasonably expected to work less than 30 hour per week
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Managing offers of coverage Monitoring enrollment trends and premium costs Preparing for IRS reporting Managing state subsidy notifications Preparing for employee inquiries 12
Employee Employer Exchanges
Employer has 90 days to appeal Exchange notifies employer of subsidies awarded Employee applies for a subsidy through the exchanges
Federal exchange is not yet releasing notifications
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in 2015
– Standard appeals form – Receive determination in 90 days of appeal – To appeal or not to appeal?
and 4980H(b) in late 2016
– Notification process has not yet been defined – Dispute process has not yet been defined
Remember: the processes for appealing subsidies and appealing tax penalties are wholly separate. 14
State Exchanges: California, Colorado, Connecticut, Hawaii,
Washington DC, Idaho, Washington, Idaho, Kentucky, Maryland, Massachusetts, Minnesota, New York, Rhode Island, Vermont
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verification
verification
for employee subsidies
are subject to fines
erroneous subsidies are necessary for individuals
are subject to penalties
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Eligibility Appeals Management IRS Reporting Fine Disputes
‘Coming Soon’
Data/audit trail is key 2016 is almost upon us Counting to 30 is difficult! Benefits Modeling and Workforce Modeling 2016+ 2016 2015 2014 2013 18