The ACA includes various new reporting requirements and fees to be implemented over a period of time. A few upcoming items which may affect your organization include the transitional reinsurance fee, health plan identifier and data reporting to the IRS.
Transitional Reinsurance Fees
Generally, self-insured plans providing major medical coverage will be subject to a fee of $63 per covered life. In order to determine an organization’s total balance due, the appropriate form must be filed by November 15, 2014. The payment will then be made via ACH which requires registration on pay.gov. For this particular fee, the first installment will be due by January 15, 2015 with a second installment due by November 15, 2015.
Certain plans are exempt from these fees, including but not limited to: stand-alone plans (e.g. vision, dental, prescription drug), Health Savings Accounts (HSAs), Health Reimbursement Arrangements (HRAs), Flexible Spending Accounts (FSAs), and Stop-Loss Coverage. Read more here.
Health Plan Identifier (HPID)
All health plans are required to obtain an HPID to be used as the standard transactional identifier for health plans when interacting with the government. Health plans other than small health plans must obtain their HPID by November 5, 2014. Small health plans must obtain their HPID by November 5, 2015. “Small health plan” is defined as a plan with $5 million or less in the previous year in claims receipts for a self-funded group, or $5 million in total premium for a fully-insured group. Read more here.
Data to Report to IRS – IRS 6056
Applicable large employers are required to file information returns with the IRS under IRS Section 6056. Applicable large employers are those with 50 or more full-time employees during the previous year (see IRS guidance on how to calculate FTE’s.) Employers file form 1094-C and 1095-C to report information on each full-time employee. Employees must also be provided with a statement of this data.
Reporting is voluntary for calendar year 2014. It will be required beginning with calendar year 2015, and forms are due by February 29, 2016. For each individual return that is incorrect or not timely filed, or not furnished to employees, a penalty ranging from $30 to $100 may be assessed. The maximum penalty for failure to file timely is $1.5 million.
Some (but not most) may qualify for simplified reporting. For more information on IRS 6056, see the Q&A on the IRS website.
