Employer SharedResponsibility Solutions Solutions Integration Customization Service
Employer Shared Responsibility Solutions Technology solutionsto alleviate the regulatory administrative burden on your organization Integrationwith existing HRMS/benefits administration systems Configuration customizedto the unique aspects of your industry and workforce, your approach to the regulations, and the capabilities/limitations of your payroll software. Our solution is not a box that you need to fit into; we shape it to fit your needs Customer focused; service orientedsupport. We are small, nimble and able to adapt in hours instead of days or weeks
Employer Shared Responsibility • Beginning in 2015, employers must comply with the Shared Responsibility mandate of the Affordable Care Act or face penalties. • Shared Responsibility mandates that employers provide their full time employees a minimum level of coverage value at an affordable cost. • Employers are now challenged with determination, administration and reporting of eligibility, affordability & value.
Solutions • Employee Full-Time Eligibility Determination • Affordability Calculation • Reporting/Exchange Response/Penalty Calculation
Eligibility & Affordability Solutions • We collect payroll and time/hours data on a per pay or monthly basis, then import into our calculation program • Our calculations are customized to the methods that best fit our clients workforce and business processes. We strive to make the process as effortless as possible on the client side • Using the payroll data already collected for eligibility, or Safe Harbors, we will test the affordability of the lowest cost qualifying medical plan
Integration & Reporting Solutions • We can integrate our calculation results with benefits administration systems and HRMS, whether it be to drive system eligibility rules or as data for reporting. • We will provide our client with information to complete IRS form 1094-C, which is the annual report for compliance. • We can also customize reporting for our clients as needed in order to have the most complete data set for the decision making process.
Service • We understand that client service is critical, and believe that putting our clients first is the only way to do business. • We are small and flexible enough to react quickly to changing needs and issues as they arise, without wrapping up processes in red tape.
Regulation Overview See our website for more information and for links to current articles and regulatory updates: www.employersharedresponsibility.com
Eligibility Determination • An hourly FTE is defined as an employee who works an average of at least 30 hrs a week over a measured month, or who works at least 130 hrs during that month. • For non-hourly employees, an employer may use either actual hours, days worked (with 8 hrs credit per day), or weeks worked (with 40 hrs credit per week) • Although the rules go into effect January, 2015, 2014 data is used for calculations
Current Employees • For existing/ongoing employees, Full Time eligibility is calculated using an annual look-back process, which takes a period of time between 3 and 12 months. There is an administrative buffer period for calculation and determination of employees for whom to offer enrollment, then a stability period where the employee maintains eligibility. • The stability period cannot be shorter than the measurement period.
New Hires • The rules for new hires become a bit more complex. • An initial measurement period of between 3 and 12 months, starting between the actual DOH and the first day of the following month is used to determine eligibility. As with existing/ongoing employees, an administrative period of up to 90 days is allowed. However, the total time frame may not exceed the last calendar day of the month of the one year anniversary of hire. • Once an employee has been employed over a standard measurement period, they become an ongoing employee.
Transition Relief for 2015 • In order to ease the determination of FTEs for the initial 2015 period, a transition approach has been adopted. For 2015 only, the measurement period: • Can be between 6-12 months • Begins on or before July 1, 2014 • Ends no earlier than September 30, 2014, or 90 days before the start of the first plan year following January 1, 2015.
Minimum Plan Value • You will work with your broker and/or benefit consultant to determine minimum plan values and any plan design changes that may need to occur. • Alternately, the Department of Health & Human Services has an online ‘calculator’ that can be used to assess whether the plan meets minimum requirements.
Affordability Calculation • The employee share of the premium of the lowest cost benefit option that meets minimum value requirements should not exceed 9.5% of the employee’s annual household income. • Safe Harbor determination of affordability can use W2/Box 1 , monthly rate of pay as of the beginning of the coverage period, or the Federal Poverty line. • Our solutions can make these calculations using any of the approved methods.
Reporting, Response & Penalty Assessment • The “Pay or Play” penalty is $2000 per year per FTE. Employers failing to offer benefits to FTE’s and dependents which meets the minimum plan value. • The “Pay and Play” penalty is $3000 per year per FTE that either receives a tax credit through the Exchange and is offered ‘affordable’ coverage or is not offered coverage and enrolls in the Exchange.