FTE Tracking and Health Coverage Reporting Thursday, September 25, - - PowerPoint PPT Presentation

FTE Tracking and Health Coverage Reporting

Thursday, September 25, 2014 2:00 pm – 3:00 pm EST

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Joe DiBella

• Executive Vice President of the Health & Welfare Practice
• Conner Strong & Buckelew

Phyllis Saraceni

• Senior Vice President, Compliance & Audit Practice Leader
• Conner Strong & Buckelew

Today’s Speakers

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Conner Strong & Buckelew’s next installment in ongoing series of webinars

• n key national healthcare reform issues
• 2015 healthcare reform planning issues
• HIPAA health plan identifier (obtained by November 5)
• Transitional Reinsurance Fee (start process by November 15)
• Full-time employee measurement / 2015 enrollment process
• New health coverage reporting forms
• Strategies to track, obtain, organize, and submit required health

coverage reporting information

Welcome and Agenda

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Patient Protection and Affordable Care Act (“PPACA” or “ACA” or HCR”)

• Repeal remains unlikely
• President standing firm on continued roll-out (w/ executive delays)
• Vulnerable members of Congress concerned with re-election
• Highly partisan House and Senate under pressure to find consensus and

address problems

• Bipartisan legislative fix opportunities unlikely to succeed - President will

veto (e.g., House bills to delay mandates and modify definition of FTE from 30 hours/week to 40)

• Growing concerns about more political fallout, particularly because of

law's convoluted connections with tax system

• IRS using website, social media, and webcasts to inform public
• Insurer connection issues between their computer systems and

government's systems

Political and Social Landscape

Taxes, Fees, and Penalties

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Can you list all taxes and changes that a 50+ group incurs? See next slide for inventory.

Participant Question

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1) Pay or Play/Employer Mandate 25) Elimination of the RDS 2) Coverage Information Reporting 26) Early Retiree Reinsurance Program 3) Track Full Time Employees 27) Over the Counter Drug Changes 4) Decide whether to Pay or Play 28) Cadillac Tax 5) Worker Classification and Time Tracking 29) Plan Amendment/Terminations 6) Non-Calendar Year Section 125 Plans 30) Automatic Enrollment 7) Prepare for Interaction with the Marketplaces 31) First Dollar Coverage for Preventive Care 8) Pre-Existing Condition Exclusion 32) Revised Appeal Process 9) PCOR Fee 33) Patient Protections 10) Transitional Re-Insurance Fee 34) Insured Non-Discrimination Rules 11) Health Insurer Fee 35) Clinical Trial Coverage 12) Prepare and Distribute Marketplace Notice 36) Transparency Reporting 13) Summary of Benefits and Coverage (SBC) 14) Prepare and Distribute SPDs and SMM 15) Wellness Program Incentive 16) 90 Day Waiting Period 17) Lifetime Limit on Essential Health Benefits 18) Out of Pocket Limits 19) Coverage for Adult Children 20) W2 Reporting for Value of Benefits 21) Recessions 22) Health FSA Contribution Limit 23) Health FSA Carry Over 24) Medical Loss Ratio Rebates

Inventory of Major HCR Requirements

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• PPACA excise tax penalties - applies to multitude of HCR requirements
• $100/day/affected individual for certain violations:
• Potentially more significant than pay or play penalties
• Example: Total potential ANNUAL excise tax per person for

continuous violation of single requirement could be $36,500

• Applies for each day failure occurs and ends on date failure corrected
• Limited correction window available - makes identifying and promptly

correcting potential errors of utmost importance

• Employers required to self-report and pay excise tax for violations using

Form 8928

Employers – Excise Tax Penalties

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Comparative Effectiveness Research Fee – Funds Patient-Centered Outcomes Research Institute (PCORI) which conducts research on effectiveness of treatments

• Annual fee of $1 per member, increasing to $2, then indexed

Health Insurance Industry Fee –Helps fund PPACA implementation

• Insured plan only
• 2% – 2.5% of premium in 2014
• 3% – 4% of premium in future years

Transitional Reinsurance Program (TRP) Fee – Annual fee intended to lessen impact of adverse selection in individual market

• $63 per member per year (PMPY) in 2014
• $44 PMPY in 2015
• $25 – $30 PMPY in 2016

Fees and Taxes/Employers and Insurers

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• Americans must pay penalty or have minimum essential coverage (MEC)

beginning 1/1/14 (unless exemption applies)

• Can buy insurance on or off exchanges - some get federal premium

(subsidy) assistance on exchange

• Exchange and tax complications await consumers
• Second open enrollment season runs Nov 15 to Feb 15
• Shorter than last year (3 months instead of 6) and overlaps with

Holiday season

• Carrier pricing and subsidy amounts changing for 2015 coverage
• New forms and line items added to 2014 tax returns (filed in

Spring 2015) – all must prove they have MEC and got correct subsidy amount (too much and tax refunds will be reduced)

Individual Mandate and the Exchange

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Employers with 50+ full-time employees (FTEs) or FT equivalents must offer affordable, minimum value medical coverage to FTEs and their children up to age 26 or face penalty.

Employer Mandate

Employer Size 2015 Plan Year 2016 Plan Year and Beyond 1-49 FTEs Does not apply Does not apply 50-99 FTEs (For 2015, must certify they are not reducing size of workforce to stay below 100 FTEs) Does not apply Employer must offer coverage to 95% of FTEs and dependents to age 26 100 or more FTEs Employer must offer coverage to 70% of FTEs and dependents to age 26 Employer must offer coverage to 95% of FTEs and dependents to age 26

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Please describe the amounts due to federal government in November for employee coverage, per person payment. See next slide for information on TRP fee due in November.

Participant Question

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• Contributions required for 2014, 2015 and 2016 benefit years
• HHS collects contributions and sets national contribution rate
• Can have TPA submit on plans’ behalf (many will not assist)
• If do not have pay.gov account, need to create account to complete TRP

contribution submission filing

• Submit enrollment count by 11/15/14 using special Form (not yet available) -

Form will automatically calculate TRP contribution amount

• Have option -
• payment of $63/covered life by 1/15/15, or
• 2 payments/year: $52.50/covered life due 1/15/15 and

$10.50/covered life due 11/15/15

TRP Fee

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Key TRP Deadlines for 2014 Benefit Year

Date Activity Contribution Amount No later than November 15, 2014 Submit Annual Enrollment Count and Schedule Contribution Payment Date No later than January 15, 2015 Remit first Contribution Amount $52.50 per covered life No later than November 15, 2015 Remit Second Contribution Amount $10.50 per covered life Total $63.00 per covered life

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TRP Contribution Submission Process Overview

Collect Data, Calculate Annual Enrollment Count and Prepare Supporting Documentation Register on Pay.gov Complete Contribution Form Enter Payment Information Upload Supporting Text

A Reporting Entity completes all of the following steps:

On Pay.gov

1 3 2 4

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Scheduling the TRP Payment

• HHS recommends scheduling payment at least 30+ days after Form submission but

before 1/15/15 deadline − This will allow for validation and correction if necessary

• Here is an example for a combined collection:

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• Self-insured employers register on Pay.gov (carriers handle TRP fee for

insured plans)

• Collect information needed to compete Form and Supporting Documentation
• Contact bank to have ALC+2 value added to allow for automatic debits (if

applicable)

• Monitor TRP guidance, including the CMS.gov “Reinsurance Contributions”

specific CCIIO webpage

• Sign up and receive notifications for training sessions on www.REGTAP.info
• Attend special TRP webinars for more information (register at

www.REGTAP.info)

• Complete TRP contribution submission process on Pay.gov beginning later

this Fall

What Can You Do to Prepare for TRP

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Please address Auto Enrollment for 200+ employees. Will this happen? Governmental guidance confirms employers not required to comply with provision until guidance is provided. To date no guidance provided, so employers currently not required to comply. Rules and regulations must be issued before implementation can happen, and time will be provided prior to implementation.

Participant Question

HIPAA Health Plan Identifier

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HIPAA requires “covered entities” conducting covered transactions electronically to use standardized formats and codes

• Applies to covered transactions involving eligibility/enrollment and

payment of health care claims

• A “controlling health plan” (CHP) is required to obtain health plan

identifier (HPID) to be used on all standard transactions conducted by plan and business associates (e.g., the claims administrator)

• Insurer is covered entity and will be completing HPID application

process

• Broad definition of CHP appears to encompass self-funded health plans

sponsored by employers

HIPAA HPID Requirement

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• Large plans with receipts over $5M must obtain HPID by November 5, 2014

(small plans have additional year to comply)

• For self-funded plans, “receipts” equal total amount paid for health

care claims during prior full plan year

• All health plans must use HPID in transactions by November 7, 2016
• Lack of clarity regarding application of requirements to self-funded employer-

sponsored health plans

• Looking for additional clarification and guidance from HHS

HIPAA HPID Requirement

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• Plan sponsors apply for HPID through Health Plan and Other Entities

Enumeration System (HPOES) - resides within CMS Health Insurance Oversight System (HIOS)

• Application process in current state not readily usable by self-funded health

plans - HIOS geared towards insurance issuers

• Instructions do not discuss how plan sponsor obtains user number needed

to access HPOES system - process for using website is not intuitive

• Additional guidance or alternative method needed for plan sponsors to

comply by November due date

• Until additional guidance is provided, sponsors of self-funded plans may

wish to wait until closer to deadline before beginning application process

HPID Application Process

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If medical, dental and vision are packaged for enrollment, can the employer request just one HPID, or is a separate HPID required for each coverage? Some employers maintain single self-funded plan for several types of coverage (medical, dental, and vision) with separate claims administrators. Others maintain multiple plans (e.g., separate plans for actives and retirees or different classes of active employees). Currently unclear what “plan” is considered a CHP (which must have HPID). Status is important because HPOES currently limits an entity (or EIN) to one HPID. HHS is aware of issue and indicates that it is being addressed.

Participant Question

Employer Mandate and Health Coverage Reporting

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Two significant ACA requirements begin January 1, 2015:

• Employer “pay or play” mandate
• Applies to employers with 100 or more FT and FT equivalent employees

in controlled group as of first plan year beginning in 2015

• Applies to employers with 50 to 99 FT and FT equivalent employees in

controlled group as of first plan year beginning in 2016 (need to certify did not reduce size of workforce to stay below 100 FTEs)

• Health coverage reporting
• Code Section 6055 and 6056 requirements effective with 2015 calendar

year.

• Does not apply to employer with fewer than 50 in controlled group, that

either (1) does not sponsor any health plan, or (2) sponsors a fully- insured health plan.

• All other employers required to report on 2015 health coverage.

Effective January 1, 2015

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• Requires affected employers offer affordable, minimum value coverage to

FTEs and dependents, or may be liable for penalty for certain of those FTEs for any month coverage is not offered

• Beginning January 1, 2015, businesses must determine for each month:
• type of health benefits offered for each month (if any), and
• whether offering health benefits to “FTEs” (working average of 30

hours/week, or 130 hours/month).

• Special FTE determination rules apply if employer has variable-hour or

seasonal employees

• Complicated look-back “measurement periods” and look-forward “stability

periods” can be applied to determine employees FT status for penalty purposes

The “Pay or Play” Employer Mandate

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How do we determine eligibility for employees with hours that fluctuate throughout the year? When an employee's hours fluctuate between <32 and >32, at which point do we move them from full-time to part-time or vice versa?

For penalty and FTE determinations, if variable hour, part-time, or seasonal employees where it is uncertain whether they are FT (average of 30+ hours/week), employers can establish

• “measurement periods” of 3-12 months to determine average hours worked,
• “stability period” for treating employees as FT or not, and
• “administrative period” to enroll employees determined to be FT.

Participant Question

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How to handle temporary employees? If temporary employee (TE) is FTE (hired to work 30+ hours/week), cannot be treated as variable hour employee. To avoid penalty, employer must offer compliant coverage no later than first day of 4th month of employment. If TE works variable hours (employer does not reasonably know hours TE will work), can track hours to determine if FT. If FT based on hours tracked, offer benefits to avoid penalty. Can use safe harbor methods and subject TE to measurement and stability period tracking.

Participant Question

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How do we determine if our seasonal employees would qualify for medical coverage? Plan eligibility language determines who qualifies. Employees classified as “seasonal” may be treated as variable. To avoid penalty for seasonal employee who works 30+ hours/week and is not otherwise eligible for benefits, may subject seasonal employee to look back and look forward measurement periods.

Participant Question

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How do you measure hours for stipend positions? No specific guidance available. Until further guidance is issued, use reasonable method of crediting hours for employees paid by stipend. Agencies considering additional rules for determination of hours for certain categories of employees whose hours are particularly challenging to identify or track, or where general rules for determining hours may present special difficulties.

Participant Question

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Employers need to finalize determinations on:

• employer size and controlled group status,
• plan year and mandate effective date,
• how they will track FT employees, and
• plan design in order to comply with employer mandate requirements

Plan sponsors using look-back and look-forward periods also need to:

• update eligibility rules for variable hour counting and employee eligibility provisions in

advance of 2015 plan year,

• update new hire guides and enrollment materials to include language describing how

sponsor defines eligible employees, and

• identify periods and descriptions for variable hour tracking, measurement periods,

stability periods, and administrative periods

Employer Mandate - Immediate Issues

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• For calendar year plans, anyone (including variable hour tracked employees)

found to be FT for January 1, 2015 will need to be offered coverage in advance of January 1, 2015 effective date to avoid potential penalty

• Therefore, tracking of hours for employees should be happening in 2014 for

most sponsors

• To avoid penalties, administrative periods have to be operational in time to
• ffer coverage and enroll newly eligible individuals in calendar year plans

effective January 1, 2015

Employer Mandate - Immediate Issues

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All employers (other than as noted below) required to report on 2015 health coverage

• Employer with fewer than 50 FT and FT equivalent employees in controlled group that

does not sponsor any health plan not subject to reporting rules

• Employer with fewer than 50 FT and FT equivalent employees in controlled group that

sponsors only fully-insured health plan not subject to reporting rules

By January 1, 2015, all affected businesses to begin tracking 2015 data on type

• f health benefits they offer (if any) and who is offered and electing these

benefits

• First statements furnished to individuals by February 1, 2016 (same timing as W-2 for

2015 calendar year information)

• First IRS transmittal forms filed by February 29, 2016 if filed on paper, or by March 31,

2016 if filed electronically

Health Coverage Reporting

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Two separate reporting requirements:

• MEC Reporting under Code Section 6055 (Forms 1094-B and 1095-B)
• related to minimum essential coverage (MEC)
• Large Employer Reporting under Code Section 6056 (Forms 1094-C

and 1095-C) - related to employer-sponsored coverage provided to FTEs

• Both involve reporting to IRS and providing statements to employees
• Electronic reporting to IRS required if filing 250+ returns
• Electronic statements to employees permitted with consent
• No tax filing penalties for 1st year if employer shows made good faith efforts

to comply (pay or play penalties still apply)

• Initial drafts of reporting forms now available; final versions to be posted at

later date

Background on Reporting

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• Draft instructions for Form 1094-B and 1095-B (MEC Reporting):

http://www.irs.gov/pub/irs-dft/i109495b--dft.pdf

• Draft Form 1094-B: http://www.irs.gov/pub/irs-dft/f1094b--dft.pdf
• Drafts Form 1095-B: http://www.irs.gov/pub/irs-dft/f1095b--dft.pdf

Note: Exchange/Marketplace insurers report MEC to covered individuals on Form 1095-A: http://www.irs.gov/pub/irs-dft/f1095a--dft.pdf

• Draft instructions for Form 1094-C and 1095-C (Large Employer

Reporting): http://www.irs.gov/pub/irs-dft/i109495c--dft.pdf

• Draft Form 1094C: http://www.irs.gov/pub/irs-dft/f1094c--dft.pdf
• Draft Form 1095-C: http://www.irs.gov/pub/irs-dft/f1095c--dft.pdf

Draft Instructions and Forms

MEC Reporting

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MEC Reporting

Form 1094-B IRS transmittal form Insurers will file for all insured employer coverage

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MEC Reporting

Form 1095-B Individual Statement Insurers will file for all insured employer coverage

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Form 1094-B and 1095-B Information reported on 1094-B (IRS transmittal) and 1095-B (individual statement) confirms each person’s MEC enrollment for each month of coverage as required by individual mandate Every person that provides MEC to individual during calendar year must file information return and transmittal

• Insurers will file 1094-B and 1095-B for all insured employer coverage
• Small employers (under 50), who self-insure their group health plans, and any

employer who offers MEC to non-employees, will file 1094-B and 1095-B

• Sponsors of multiemployer plans will report coverage on Form 1095-B
• All applicable large employers (ALEs) over 50, including government employers, will

report MEC on Form 1095-C

MEC Reporting

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Do Union representatives have an obligation to provide health plan information to the employer, i.e., type of plan, who is specifically covered? If not, how can the employer report it to the IRS? If coverage provided through multiemployer health plan, plan provides coverage information to enrolled employees, and employer should not complete Form 1095-C (Part III) for those employees. Sponsors of multiemployer plans report coverage information to enrolled employees on Form 1095-B (individual statement).

Participant Question

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Form 1094-B and 1095-B Examples of data required to be reported include:

• Name, address, and EIN of reporting entity
• Name address and SSN of each responsible individual
• Name and SSN of each covered individual
• Months of coverage during calendar year
• For insured group health plans, name, address, and EIN of employer sponsoring plan

MEC Reporting

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For 2015 reporting of dependent coverage, how is that reported if medical coverage and prescription coverage are provided by 2 separate insurers? Each insurance issuer will file a Form 1095-B (employee statement) for insured employer coverage they provide.

Participant Question

Large Employer Reporting

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Form 1094-C and 1095-C Information reported on Form 1094-C (IRS transmittal) and 1095-C (employee statement) confirms employer’s compliance with employer mandate and confirms MEC enrollment as required by individual mandate

• An ALE (over 50) files 1094-Cs and 1095-C for each FTE (whether or not offered

coverage) for any month of calendar year (each employer has own reporting

• bligation)
• Employer that offers SI health plan must complete 1095-C (Part III) for any individual

(FTE, non-FTE, employee family members, and others) who enrolled in SI plan

• If coverage is insured or through multiemployer plan, issuer or sponsor will

report MEC on Forms 1094-B and 1095-B for those enrolled employees

• A small employer (under 50) that provides SI health coverage is not required to file

Forms 1094-C and 1095-C and reports instead on Forms 1094-B and 1095-B for employees who enrolled in SI coverage

Large Employer Reporting

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Large Employer Reporting

Form 1094–C IRS transmittal form Employers will use to report summary information to IRS and to transmit Forms 1095-C to IRS

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Large Employer Reporting

Form 1095-C Employee statement Provided by large employer and used for:

• 1. reporting coverage

information about each employee

• 2. determining whether

employer owes pay or play penalty

• 3. determining eligibility of

employees for premium tax credits

• 4. reporting information to

IRS and employees about individuals covered by MEC under employer plan and therefore not liable for individual mandate payments

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Form 1094-C and 1095-C Examples of data required to be reported include:

• Employer name and EIN and contact person’s name and phone number
• Number of FTEs by month
• Whether employer coverage provided MEC, minimum value, met 9.5%

affordability test, and offered to FTEs and dependents

• Each FTE’s share of lowest cost monthly premium for self-only coverage of

minimum value standards, by calendar month

• Name address and SSN for each covered individual (whether FT or not),

and each month of coverage Simplified reporting options apply for certain employers who can certify that they meet special “offer methods” or “transition relief”

Large Employer Reporting

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Form 1094-C (IRS transmittal)

• Employer certifies it made “qualifying offer” for all months employee was

FT and penalty payment could apply

• Minimum value coverage, with affordable employee contribution for

employee-only coverage

• Offered coverage for spouse and dependents, regardless of minimum value
• r cost
• Instead of Form 1095-C, employer can send statement with:
• Employer name, address, EIN, contact name, telephone number
• Statement that for all 12 months of calendar year, employee, spouse and

dependents received Qualifying Offer and not eligible for premium tax credit

• Other offer methods and transition relief options available that offer

simplified reporting

IRS Transmittal: Qualifying Offer

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• Each ALE member must file Form 1094-C providing that ALE member’s EIN

(regardless of size)

• One “Authoritative Transmittal” reports aggregate employer level data and

identifies any “Aggregated ALE Group” members

• ALE member responsible for filing penalties
• Governmental Unit may report on own behalf, or may designate another

person to report related to same governmental entity - designated person can assume reporting penalty obligation, but not mandate penalty obligation

• Multiemployer plan administrator can prepare return for ALE members

covered by CBA under multiemployer plan

• ALE files returns for other employees not eligible to participate in

multiemployer plan

• Plan administrator files separate returns for each ALE member that

contributes and can assist with individual returns

ALE Member Reporting

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Form 1095-C (employee statement) Some employee statement information is reported using indicator codes

Employee Statement: Indicator Codes

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Employee Statement: Indicator Codes

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For each FTE of an ALE Member, there must be only one Form 1095-C for employment with that ALE Member

• Example: If employer separately reports for FTEs of 2 divisions, employer

must combine information for employee who worked at both divisions during calendar year so there is single Form 1095-C for that employee which reports information for all twelve months of calendar year

• In contrast, FTE who works for more than one employer that is member of

same Aggregated ALE Group (that is, works for two separate ALE Members) must receive separate Form 1095-C from each employer

Employee Statement: One 1095-C for Each Employee

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• Parent, Sub A, and Sub B are all in common control. For 2015:
• Parent had 500 FTEs (averaging 30+/week) and 500 part-time

employees Sub A had 250 FTEs and 250 PTEs

• Sub B 100 FTEs and 100 PTEs
• Same SI plan covers all 3 companies for all of 2015 and plan includes at

least 1 option that meets affordability and minimum value standards

• Plan offers coverage to all FTEs, spouses, and children up to age 26
• Only PTEs in certain locations get offers (and their spouses and children)
• Filings:
• Parent can file 3 separate Forms 1094-C (for Parent, Sub A, and Sub

B) with accompanying Forms 1095-C, or

• Each company can file its own Form 1094-C with accompanying

Forms 1095-C

Example: Large Employer Reporting

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(example continued) For Parent company 1095-C individual statements:

• All 500 FTEs are eligible for coverage; 450 enroll
• 100 of the 500 PTEs are eligible; 25 enroll
• Filings: Parent must file 525 Forms 1095-C
• 1 for every FTE, regardless of whether he/she enrolls, even if FT for
• nly part of year
• 1 for every employee who enrolls, regardless of PT or FT status

Example: Large Employer Reporting

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Are there 3rd Party companies that can handle the IRS reporting? As with Form 5500 filings, certain attorneys, enrolled agents, certified public accountants, benefits professionals, and other individuals could presumably prepare, or assist in preparing, new IRS health coverage reporting forms. However, any preparer must rely on employer to provide Information needed to complete Forms. Employers must be tracking and collecting 2015 data, and identifying now a method to collect and measure required information (may require deployment

• f special enrollment system or creation of additional process or capability

within HR department). A third party may enter into reporting arrangement, but no assumption of reporting penalty or mandate penalty.

Participant Question

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• Know requirements and deadlines
• Prepare for TRP fee (if applicable)
• Prepare for HIPAA Health Plan Identifier process (if applicable)
• Full implementation of measurement periods and tracking of FTEs
• Amend plan documents, SPDs, OE/new hire materials to reflect changes

to waiting periods, eligibility, plan design, measurement periods, etc.

• Strategize how to collect required data for FTE and coverage information

filing

• Identify 3rd parties to assist with collecting and reporting required

information

• Start planning for Cadillac tax in 2018 (entities with high cost plans, put

plan design/labor contract negotiation strategies in place to protect against potentially exorbitant tax)

Planning and Next Steps

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Agency Resources

Agency Healthcare Reform Sites: Health and Human Services (HHS): http://healthcare.gov/ Department of Labor (DOL): http://www.dol.gov/ebsa/healthreform/ Internal Revenue Service (IRS): http://www.irs.gov/newsroom/article/0,,id=220809,00.html?portlet=6

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Help from Conner Strong & Buckelew

Conner Strong & Buckelew Healthcare Reform website page at:

http://www.connerstrong.com/healthcare_reform

» News updates » Online library of client updates and alerts » Summary of major provisions of the new law » Detailed Year-by-Year timeline of changes » Outline of all aspects of the new law Check back for updates, news and analysis, and updated tools to help you navigate this complex process Call Conner Strong & Buckelew at 877-861-3220

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Other Resources from Conner Strong

Periodic Webinars

• Web-based presentations on health

care legislation, regulations and innovative ideas Email Alerts and Updates

• High level, quickly produced articles

about emerging issues intended to alert clients to legislative and regulatory developments

• Historic library available on line

Perspectives

• Thought pieces intended to identify

trends and issues, helping clients anticipate challenges

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Thank you for your participation!

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