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2016<br />

<strong>ACA</strong> IRS Compliance<br />

Kenneth F. Phillips<br />

Benefit Corporation of America, LLC.<br />

www.benefitscape.com<br />

508.655.3307


Introduction<br />

Thank you for providing the necessary data needed to prepare your <strong>ACA</strong> IRS filing for 2015.We<br />

are confident that the codes we have calculated for the IRS Form 1095C accurately reflect the<br />

data you have provided.<br />

The next step is for you to review the results that we have determined based on your data. By<br />

“review” we propose that you look o<strong>ver</strong> the data for accuracy and completeness.<br />

What we need you to do next<br />

There are PDF forms in your Sharefile 1 with the information to review. You should<br />

download the PDF forms and look them o<strong>ver</strong>. <strong>Instructions</strong> are on the next page.<br />

What we have done to insure accuracy and completeness<br />

Step 1.<br />

Disco<strong>ver</strong>y<br />

We have taken all of the plan rules, company data and applied the <strong>ACA</strong><br />

IRS rules to your Organization.<br />

Step 2.<br />

Processing your<br />

Data<br />

We have taken your employee data, tested its accuracy and processed all<br />

of the data to determine which employees are to be reported to the IRS.<br />

Step 3.<br />

Producing your<br />

Reports<br />

The employee data is then processed by our systems to produce the<br />

‘results’ required by the IRS. These results are printed onto the Form<br />

1095C and prepared for publishing and mailing to each employee.<br />

These are the FORMS that you have to review<br />

After you have reviewed the forms you should communicate your<br />

comments to us. We will make the necessary corrections (if any are<br />

needed) and Print and Mail the <strong>Forms</strong> to your employees.<br />

Congratulations! Your compliance effort for 2015 is complete.<br />

1 If you do not know how to get access to your Share Folders please send us an email and we can help. y<br />

2 | Page Confidential 2016 BCA


How to review your forms<br />

The first item to review for accuracy is that the Company information is correct.<br />

Next step, please review the various codes.<br />

Step 1. <strong>Forms</strong><br />

Review<br />

This is a 2 step<br />

process<br />

1. Check the<br />

Company<br />

Information.<br />

Make sure the<br />

phone number is<br />

correct!<br />

2. Review the<br />

OFFER codes for<br />

each employee.<br />

These are the possible OFFER Codes:<br />

<br />

<br />

1A or 1E means an offer of co<strong>ver</strong>age was made<br />

1H means no offer of co<strong>ver</strong>age was made<br />

The Safe Harbor codes are the reasons or the result for a certain offer.<br />

We determined these codes based on your employee data and plan rules.<br />

Additional common codes are:<br />

2C indicated the employee took the OFFER and has co<strong>ver</strong>age in the<br />

months shown.<br />

2F, 2G 2H indicate employee waived the offer and has no co<strong>ver</strong>age in the<br />

months shown.<br />

2A indicates the employee was not hired at the company.<br />

A complete listing of all the Codes that are available and their explanations are<br />

included in the Appendix attached to this document.<br />

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For Self Funded Plans (Not Fully Insured)It is necessary to show co<strong>ver</strong>age for<br />

each individual by month, check to see if the data appears correct.<br />

If any corrections are needed<br />

In addition to the above; we have provided you with a Spreadsheet with all of the Codes<br />

calculated for each employee (including any dependent information for each employee,<br />

if that information was required.)If you have any corrections you can highlight the errors<br />

on this Spreadsheet and put it back into the Sharefile. Then send us an email and we<br />

will set up a webinar or phone call.<br />

Remember: If the data contains personal information i.e. SSN do not send via email.<br />

Save and upload on the Secure Citrix Sharefile.<br />

If it’s all OK<br />

Send us an email and let us know you are ready for us to publish the <strong>Forms</strong>.We will<br />

then -<br />

Print the <strong>Forms</strong> for each person,<br />

Mail them to each employee’s address provided in the data<br />

The follow up…After the forms are mailed, some may come back for bad address,<br />

or there may be questions on the information.<br />

The best way to handle this is by email (if no personal information is involved).<br />

If you have certain information that is confidential please place it in the Secure Citrix<br />

Sharefile and send us an email explaining the situation.<br />

4 | Page Confidential 2016 BCA


Appendix<br />

IRS Form 1095-C - Line 14 - Offer of Co<strong>ver</strong>age Codes Lines 14, 15, and 16<br />

Offer of co<strong>ver</strong>age codes should not be confused with the whether the employee<br />

accepted the co<strong>ver</strong>age. The code indicates that you as the employer provided an “offer<br />

of health co<strong>ver</strong>age to the employee” and is not affected by the employee acceptance of<br />

the offer or if the employee rejects the offer (a wai<strong>ver</strong>).<br />

We have entered an offer of co<strong>ver</strong>age for all 12 months if the employee was a<br />

full-time employee for one or more months during the year.<br />

VERY IMPORTANT - Regarding using codes 1A through 1F, the co<strong>ver</strong>age offered must<br />

be applied to e<strong>ver</strong>y day of the month. If the offer is less than for a full month codes<br />

1A/1E should NOT be used. If the employee only worked part of the month, then the<br />

only codes that should be used is 1H (No Offer).<br />

Situation<br />

MEC providing MV offer made to employee,<br />

dependents, and spouse.<br />

MEC providing MC offer made to employee only.<br />

MEC providing MC offer made to employee and<br />

dependents (not spouse).<br />

MEC providing MC offer made to employee and spouse<br />

(not dependents).<br />

MEC providing MC offer made to employee,<br />

dependents, and spouse, but cost is more than 9.5% of<br />

po<strong>ver</strong>ty line.<br />

MEC providing MC offer made to employee,<br />

dependents, and spouse, but no minimum essential<br />

value.<br />

MEC providing MC offer made to employee who was not<br />

a full-time employee for any month during the year and<br />

enrolled in co<strong>ver</strong>age for one or more months.<br />

No offer of co<strong>ver</strong>age.<br />

Quality Offer Transition Relief - Employee and spouse<br />

or dependents received no offer of co<strong>ver</strong>age, received<br />

an offer that is not a qualifying offer, or received a<br />

qualifying offer for less than 12 months.<br />

Offer of Co<strong>ver</strong>age Code<br />

1A<br />

Common<br />

1B<br />

Uncommon<br />

1C<br />

Uncommon<br />

1D<br />

Uncommon<br />

1E<br />

Common<br />

1F<br />

Uncommon<br />

1G<br />

Uncommon<br />

1H<br />

Common<br />

1I<br />

Uncommon<br />

MEC = Minimum essential co<strong>ver</strong>age<br />

MV = Minimum value<br />

Other Situations: Employee terminated and offered COBRA co<strong>ver</strong>age - Use 1H<br />

5 | Page Confidential 2016 BCA


IRS Form 1095-C - Line 15 - Employee Share of Lowest Cost Monthly Premium,<br />

for Self- Only, Minimum Value Co<strong>ver</strong>age<br />

Complete Line 15 only if code 1B, 1C, 1D, or 1E is entered on Line 14. The amount entered<br />

is the cost you would charge the employee for self-only co<strong>ver</strong>age providing minimum<br />

essential co<strong>ver</strong>age providing minimum value. This amount may NOT be the amount the<br />

employee is actually paying for co<strong>ver</strong>age, for example, if the employee enrolled in family<br />

co<strong>ver</strong>age and is paying $ 110 a month, but the amount that would be charged for selfco<strong>ver</strong>age<br />

only is $ 90, you would enter $ 90 on line 15.<br />

VERY IMPORTANT - An entry on line 16 is optional. We enter the appropriate<br />

code to fully describe the enrollment to the employee. Balnks tend to confuse<br />

and look like errors.<br />

Situation<br />

Employee not employed during month<br />

Employee not a full-time employee for<br />

the month and did not enroll in<br />

co<strong>ver</strong>age offered or employee was a<br />

full-time employee and co<strong>ver</strong>age ended<br />

before the end of the month because<br />

the employee terminated employment.<br />

Employee enrolled in co<strong>ver</strong>age offered.<br />

Employee in an assessment period and<br />

not eligible for co<strong>ver</strong>age.<br />

4980H Safe Harbor<br />

Code<br />

2A<br />

2B<br />

2C<br />

2D<br />

Use<br />

employees not yet<br />

employed<br />

Common<br />

Uncommon<br />

employees who take<br />

co<strong>ver</strong>age<br />

Common<br />

in waiting period<br />

Common<br />

Multi employer interim rule relief. 2E Uncommon<br />

W-2 earnings used to determine<br />

affordability - code must be used for all<br />

months that the employee was offered<br />

co<strong>ver</strong>age.<br />

Federal po<strong>ver</strong>ty line used to determine<br />

affordability.<br />

2F<br />

– Line 14 will<br />

probably be 1E<br />

2G<br />

- Line 14 will be 1A<br />

For wai<strong>ver</strong><br />

Common<br />

For wai<strong>ver</strong><br />

Common<br />

Rate of pay used to determine<br />

affordability.<br />

Non-calendar year transition relief.<br />

2H<br />

- Line 14 will be 1E<br />

2I<br />

For wai<strong>ver</strong><br />

Common<br />

Non calendar plans<br />

Uncommon<br />

6 | Page Confidential 2016 BCA

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