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Brown & Brown — Conference Presentation (December 2023)
30 slides from Brown & Brown's conference presentation, December 2023
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 2023 Calendar Year Reporting Presented By: Scott Wold and Daniel Brady 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 that are Applicable Large Employer (ALE) self-insured and ALEs ALE = Employer that employed reporting coverage under on average at least 50 FT and self-insured plan for non- FTE employees
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 – Statements to Employees
Reporting Deadlines – Statements to Employees Due Date for Furnishing Forms 1095-B and 1095-C • March 1, 2024 (30 days from January 31) » Paper delivery » Electronic only if the individual has consented to electronic delivery of the 1095 (in writing) » No additional extensions for furnishing 1095 Fo
Slide 7: Reporting Deadlines – Filing with IRS
Reporting Deadlines – Filing with IRS Deadline to File Forms 1094 and 1095 B/C with IRS • February 28, 2024, if filing on paper • April 1, 2024, if filing electronically » Beginning in 2024, ALEs/plan sponsors that issue ten (10) or more If the due date falls on a weekend returns in aggregate (meani
Slide 8: Reporting Penalties
Reporting Penalties Imposed if furnishing and/or reporting deadlines are missed or incorrect information is furnished/reported: • $310 penalty for each form (can apply twice if failures relate to IRS submission and individual copy) • Capped at $3,783,000 (again, can apply twice) • Errors corrected o
Slide 9: Form 1095-C
Form 1095-C
Slide 10: Form 1095-C – Part 1
Form 1095-C – Part 1 Your number Last 4 digits for EE copy only – full SSN for IRS Include country 99-9999999 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 BROWN & BROWN | 11
Slide 12: Form 1095-C – Line 14 Codes
Form 1095-C – C Line 14 1A Qualifying Offer: MEC providing MV offered to employee that is affordable under FPL safe harbor and at least MEC offered to spouse & dependent(s) 1B Minimum essential coverage providing minimum value offered to employee only 1C MEC providing MV offered to employee and at l
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 that the employer is not subject to a penalty for failing to offer an individual coverage (e.g., employee is in an initial measurement period), or despite the offer of affordable coverage (subject to the affordability safe harbors) th
Slide 16: Form 1095-C – Line 16 Codes
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 2023 Affordability Safe Harbors • Codes 2F, 2G and 2H • The safe harbor percentage for plan years beginning in 2023 is 9.12% (IRS Rev. Proc. 2022-34) » Decreases to 8.39% for plan years beginning in 2024 • Three affordability safe harbors » The employee’s W-2 wages (Box 1)
Slide 18: Limited Non-Assessment Period
Limited Non-Assessment Period CODE 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
Slide 19: Form 1095-C Part III
Form 1095-C Part III Each individual In lieu of covered under the SSN plan – including the employee Each covered individual's SSN Complete Part III ONLY if self-insured health coverage • Complete for all covered employees (including any employees not considered • Include SSN (use birthdate per “soli
Slide 20: Self-Insured Employers
Self-Insured Employers Reporting for Certain Covered Part-Time Employees, Covered Former Employees and Other Covered Non-Employees • Includes the following individuals who were not a full-time employee during any month of the year » Part-time employees » Retirees » COBRA beneficiaries » Non-employee
Slide 21: COBRA
COBRA COBRA for terminated employee: • Month of termination: » 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
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 and need not report the HRA Insured major medical plan and an HRA • Not required to report on coverage under the HRA if the individual is eligible for the HRA because the individual enr
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 Employer info Authoritative # of 1095s Transmittal MEC providing MV, FPL Safe Harbor - Includes offer to spouse and Controlled group dependents rules (Alternate Employee Statement Affordable MV to 98% permitted, but not required) EE & dep & 1095-C submitted for all 12 months
Slide 25: Form 1094-C Part III
Form 1094-C Part III Check “All 12 Months” Check here if Line if offered to at least 21 is checked “yes” 95% FT employees for entire year NOT required if 98% offer method is checked on line 22 Include all employees including non-FT # FT employees for each employees & employees month – do not include
Slide 26: Form 1094-C Part IV
Form 1094-C Part IV Complete if Line 21 is checked “yes,” largest ALE Member to smallest ALE Member BROWN & BROWN | 26
Slide 27: State Individual Mandate Reporting
State Individual Mandate Reporting • IRS due date extensions and reporting relief will not automatically 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 a
Slide 28: Where to Find the Forms and Other Guidance
Where to Find the Forms and Other Guidance 2023 Instructions for Forms • https://www.irs.gov/pub/irs-prior/i109495c--2023.pdf • https://www.irs.gov/pub/irs-pdf/i109495b.pdf 2023 Forms 1095 • https://www.irs.gov/pub/irs-pdf/f1095c.pdf • https://www.irs.gov/pub/irs-pdf/f1095b.pdf 2023 Forms 1094 • htt
Slide 29: HRCI and SHRM Credits
HRCI and SHRM Credits This Program, ID No. 646607, 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 Profess
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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