PPACA Annual Reporting is required for calendar year 2016
2016 marked the start of Employer Mandate compliance under the Patient Protection and Affordable Care Act (PPACA). If you are a “Large Employer” (more than 50 full time equivalent employees), the Employer Mandate requires you to offer “Affordable, Minimum Essential Coverage” to all full time equivalent employees. Employers who do not meet these requirements will face steep penalties.
As a Large Employer, you are subject to annual reporting to substantiate compliance with the requirements of the Act. The IRS has released 1095 and 1094 series forms and transmittals to report details of coverage starting with the 2016 calendar year. Employees must be provided with a completed form 1095-C for 2016 coverage by January 31, 2017. Employers must also submit copies of the Employee forms and Summary by FEIN to the Internal Revenue Service. Paper submissions are due by February 16, 2017 and electronic filing must be done by March 31, 2017.
All individuals included in an employee’s coverage are also part of the new reporting. Self- insured employers must include the details of all covered individuals on the 1095-C form. For Employers who are fully insured, insurance carriers must provide a separate form (1095-B) to employees to detail covered individuals in addition to the 1095-C provided by the Employer. Carriers will file copies of the forms with the IRS along with the 1094-B transmittal form. As with W2 filing, the 1095 and 1094 forms are to be summarized and filed by Federal ID numbers. In most cases, if you have multiple FEINs within your organization, you will need to submit a summary form separately for each FEIN.
Regardless of who prepares the forms, as the Employer, you are responsible for compliance with all regulations of the Act. At this point in time, you should be actively working with your Insurance Carriers, Third Party Administrators and Payroll Vendor to determine who will be producing the required forms for your organization. Depending on Plan funding, you may need to implement multiple approaches for Annual Reporting. See the Information below for the various data elements you will need to compile within your organization to complete the forms – this is your data challenge!
PPACA DATA TRACKING
Employee Name and Address
Employee Social Security Number
Employer Name and Address
Aggregate Group Association
Employer Contact Information
Monthly Offer of Coverage Code by Month for each Employee
Monthly Lowest Tier Cost by Plan by Month for each Employee
Applicable Safe Harbor Code by Month by Employee
Employee Status by Month for each Employee
For Each Covered Individual:
o Social Security Number or Birthdate
o Plan Enrollment by Month by Individual
Total Headcount by Month by Employer FEIN
Total “ACA” Full Time Headcount by Month by Employer FEIN
Total number of 109-C forms filed by FEIN
Wise Consulting can help you conquer your Data Challenge!
This reporting represents a new challenge for employers as the data is diverse and most likely housed in multiple systems, perhaps inside and outside your organization. Although the forms are filed annually, the data included is detailed by month at an employee level so monthly tracking of a large volume of data will be required.
The task of compiling this data can be overwhelming with many questions you will need to answer:
· Which forms apply to my organization (self-insured vs. fully insured)?
· Who will prepare the required forms?
· What data do we need to collect, analyze and track?
· Where do we house the needed data?
· Are there data elements needed that are not currently tracked?
· Do we have access to all the data? (may be in Vendor or Third Party systems)
· Do we need to update interfaces to send or receive needed data?
The biggest question for you and your organization may be – How do I meet the challenge?
Wise Consulting has been providing services to help clients manage and analyze data for 20 years. We know the challenges you will face working to identify, track and compile data to meet the extensive PPACA Reporting Requirements.
Our Consultants can walk you through the process to develop and implement a data plan for your organization. Working with internal cross functional Resources, Vendors and Benefit Providers we will identify the source and approach for all your data requirements!
You may need to update or create new interfaces to support the sharing of data - our Technical team can support updates to or development of new files!
You may need to request data from employees that you have not collected in the past - we can facilitate the implementation of a Communication and Data Collection plan!
Finally, we can support vendor requirements for data import to provide the needed data for 2016 and future Annual Reporting and ongoing collection, analysis and tracking.
Contacting Wise Consulting
For more information, or to set up a call with your team to discuss, please email Rhonda Brill at RBrill@WiseConsulting.com or call our headquarters office at 800-654-4550.