As BAS is working with clients in the final hours of data collection for Affordable Care Act (ACA) compliance, we have come across several items that may apply to many employers.
1. Benefit Eligibility. It is important to properly classify each employee. Many employers offer benefits to employees working a certain number of hours that is less than 30 hours per week. For ACA, full-time is defined as 30 hours per week (130 hours per month). If your benefits class structure includes employees working less than 30 hours per week, you must separate out the employees so that you do not over-identify your full-time workforce.
2. Coverage for Spouses/Dependents. When you identify offers of coverage for each plan, remember to consider if some members of the benefits class are entitled to employee-only coverage and if others are entitled to coverage with dependents. Properly identifying who is eligible for coverage is necessary to ensure proper completion of Form 1095-C.
3. Payroll File. Organizations with a consolidated payroll company should confirm that the payroll company is properly recording hours for all employees. In some cases, an individual may receive pay when he is no longer an employee. For example, a vacation payout or severance payment after termination of employment may appear on a payroll file. If the payroll company identifies the after-employment payment with hours worked, Form 1095-C reporting will be incorrect.
4. Lowest Cost Plan. When employees receive Form 1095-C in early 2016, they will see a dollar figure identified for the lowest cost single-coverage plan offered to that individual. This dollar amount may or many not be the actual dollar amount the employee is paying for coverage. This line of the Form 1095-C is sure to raise questions.
5. Proper TIN and Controlled Group. Employers must make sure to properly identify Taxpayer Identification Numbers for all members of its controlled group.
Employers should consider these items and more when making the final preparations for 2015 ACA reporting compliance.