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Brown & Brown — Conference Presentation (November 2022)
30 slides from Brown & Brown's conference presentation, November 2022
Slide 1: This Webinar Will Start Momentarily
This Webinar Will Start Momentarily. Thank you for joining us.
Slide 2: ACA Reporting, Are You Ready?
ACA Reporting, Are You Ready? For 2022 Calendar Year Reporting Presented By: Brown & Brown Regulatory and Legislative Strategy Group
Slide 3: Disclaimer
DISCLAIMER Brown & Brown, Inc. and all its affiliates, do not provide legal, regulatory or tax guidance, or advice. If legal advice counsel or representation is needed, the services of a legal professional should be sought. The information in this document is intended to provide a general overview o
Slide 4: Forms
Forms Forms Forms Forms 1094-A & 1095-A 1094-B & 1095-B 1094-C & 1095-C Marketplace (exchange) Issuers, non-ALEs (less Applicable Large Employer than 50 FTE) that are self- (ALE) insured and ALEs reporting coverage under self-insured plan for non-employees BROWN & BROWN | 4
Slide 5: The Big Picture
The Big Picture ALEs sponsoring ALEs sponsoring Non-ALEs sponsoring self-insured plans insured plans self-insured plans Form 1095-C: Form 1095-B Form 1095-C: Part I, Part II and Part I and Part II only Part III Form 1094-B Form 1094-C Form 1094-C BROWN & BROWN | 5
Slide 6: Reporting Deadlines
Reporting Deadlines I R S P R O P O S E D R E G U L AT I O N S Due Date for Furnishing Forms 1095-B and 1095-C • An ALE member must furnish a Form 1095-C to each of its full-time employees by March 2, 2023, for the 2022 calendar year. Alternate Method for Providing Form 1095-B • Alternative method f
Slide 7: Reporting Deadlines
Reporting Deadlines Form 1095 (Employee/Participant Statement) • March 2, 2023 » Paper delivery » Electronic only if the individual has consented to electronic delivery of the 1095 (in writing) If the due date falls on a weekend or legal holiday, » No additional extensions for furnishing 1095 Forms
Slide 8: Reporting Penalties
Reporting Penalties Imposed if reporting deadlines are missed or incorrect information is reported: • $290 presumptive penalty for each form (can apply twice if failures relate to IRS submission and individual copy) • Capped at $3,532,500 (again, can apply twice) • Errors corrected on or before 30 d
Slide 9: Form 1095-C
Form 1095-C
Slide 10: Form 1095-C – Part 1
Form 1095-C – Part 1 Last 4 digits for EE copy only – full Your number SSN for IRS 99-9999999 Include country BROWN & BROWN | 10
Slide 11: Form 1095-C – Line 14
Form 1095-C – C Line 14 Do not leave blank Use if same for all 12 months Offer of coverage means it was offered for the entire month • 1A Qualifying Offer • 1G Offer to employee who was not an FTE and enrolled in • 1B MEC providing MV offered to EE only self-insured coverage • 1C MEC providing MV of
Slide 12: Form 1095-C – Line 14
Form 1095-C – C Line 14 Qualifying Offer: MEC/MV offered to employee, self-only coverage < than 9.61% single - 2022 federal poverty line and 1A at least MEC offered to spouse & dependent(s) 1B Minimum essential coverage providing minimum value offered to employee only 1C MEC/MV offered to employee a
Slide 13: Form 1095-C Individual Coverage HRA (ICHRA)
Form 1095-C Individual Coverage HRA (ICHRA) 1L ICHRA offered to employee only with affordability determined by using employee’s primary residence location zip code 1M ICHRA offered to employee and dependents with affordability determined by using employee’s primary residence location zip code 1N ICH
Slide 14: Form 1095-C – Line 15
Form 1095-C – C Line 15 Employee share of the lowest cost monthly premium for self-only MV coverage available to that employee Leave blank if using Codes 1A, 1F, 1G, 1H, 1R or 1S in box 14 • 1A Qualifying Offer • 1R Unaffordable ICHRA • 1F MEC but not MV • 1S ICHRA offered to non-full-time employee
Slide 15: Form 1095-C – Line 16
Form 1095-C – C Line 16 Indicates whether EE elected coverage, or a proper offer was made or affordability safe harbor, etc. Instructions provide an ordering rule for the codes • 2C Employee enrolled in the coverage • 2D Employee in a limited non-assessment period • 2A Employee not employed during t
Slide 16: Form 1095-C – Line 16
Form 1095-C – C Line 16 2A Employee not employed during the month 2B Employee not a full-time employee, or full-time employment and offer of coverage ended before end of the month 2C Employee enrolled in coverage offered 2D Employee in a section 4980H(b) Limited Non-Assessment Period 2E Multiemploye
Slide 17: Affordability Safe Harbor
Affordability Safe Harbor 2022 Affordability Safe Harbors • The safe harbor percentage for plan years beginning in 2022 is 9.61% (IRS Rev. Proc. 2021-36) » Decreases to 9.12% for plan years beginning in 2023 • Three affordability safe harbors » The employee’s W-2 wages (Box 1) X safe harbor percenta
Slide 18: Limited Non-Assessment Period
Limited Non-Assessment Period *2D • First Year as an ALE Period (January – March) • Waiting Period under the Monthly Measurement Method • Waiting Period under the Look-Back Measurement Method • Initial Measurement Period and Associated Administrative Period under the Look-Back Measurement Method • P
Slide 19: Form 1095-C Part III
Form 1095-C Part III Each individual covered under In lieu of SSN the plan – including the employee Each covered individual's SSN Complete Part III ONLY if self-insured health coverage • Complete for all employees covered including those not considered full- • Include SSN (use birthdate per “solicit
Slide 20: Self-Insured Employers
Self-Insured Employers Some Part-Time Employees, Former Employees and Other Covered Non-Employees • Part-time employees that do not work as a full-time employee during any month of the year • Retirees • COBRA beneficiaries • Non-employee directors Code 1G goes in the all 12 months column on line 14
Slide 21: COBRA
COBRA COBRA for terminated employee: • Coverage goes to end of the month in which employee terminates (1E, 2C) • Coverage does not go to the end of the month in which employee terminates (1H, 2B) • All months following the month in which the employee terminates (1H, 2A) • COBRA participants who have
Slide 22: Special Rules for HRAs
Special Rules for HRAs Self-insured major medical plan and an HRA • Report only the major medical plan information Insured major medical plan and an HRA • Not required to report if the individual is eligible for the HRA because the individual enrolled in the insured major medical plan HRA must be re
Slide 23: 1094-C
1094-C • Provides employer information • IRS uses to determine applicability of Employer Shared Responsibility Penalties Companies may use more than one 1094-C, such as for separate divisions, but only one 1094-C may be designated as “authoritative” which will contain aggregated company data BROWN &
Slide 24: Form 1094-C Parts I & II
Form 1094-C Parts I & II # of 1095s Authoritative Employer info Transmittal MEC, MV, FPL Safe Harbor - Includes offer to spouse and dependents (Alternate Employee Statement permitted, but Controlled not required) group rules Affordable MV to 98% EE & dep & 1095-C submitted for all 12 months BROWN &
Slide 25: Form 1094-C Part III
Form 1094-C Part III Check “All 12 NOT required if 98% Check here if Line Months” if offer method is 21 is checked offered to at # FT employees for checked on line 22 “yes” least 95% FT each month – do not employees for include EE in entire year Limited Non- Assessment Period Include all employees i
Slide 26: Form 1094-C Part IV
Form 1094-C Part IV Complete if Line 21 is checked “yes,” largest to smallest BROWN & BROWN | 26
Slide 27: State Individual Mandate Reporting
State Individual Mandate Reporting • The IRS due date extensions and reporting relief will not apply to state individual mandate reporting requirements • Employers with employees working in the following states may face earlier reporting deadlines and will want to ensure they are meeting all state m
Slide 28: Where to Find the Forms and Other Guidance
Where to Find the Forms and Other Guidance 2022 Draft Instructions for Forms • https://www.irs.gov/pub/irs-dft/i109495c--dft.pdf • https://www.irs.gov/pub/irs-dft/i109495b--dft.pdf 2022 Forms 1095 • https://www.irs.gov/pub/irs-pdf/f1095c.pdf • https://www.irs.gov/pub/irs-pdf/f1095b.pdf 2022 Draft Fo
Slide 29: HRCI and SHRM Credits
HRCI and SHRM Credits This Program, ID No. 609967, has been approved for 1.00 HR (General) recertification credit hours toward aPHR™, aPHRi™, PHR®, PHRca®, SPHR®, GPHR®, PHRi™ and SPHRi™recertification through HR Certification Institute® (HRCI®). Brown & Brown is recognized by SHRM to offer Professi
Slide 30: Find your solution at BBrown.com
Find your solution at BBrown.com DISCLAIMER: Brown & Brown, Inc. and all its affiliates, do not provide legal, regulatory or tax guidance, or advice. If legal advice counsel or representation is needed, the services of a legal professional should be sought. The information in this document is intend
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