Preparing Employers for 2016 ACA Information Reporting: Lessons From 2015 Compliance Missteps

Description

The complexity of the ACA information reporting provisions presented several challenges for employers during 2015 reporting, including discovering that their health plans were out of compliance with the ACA in some areas; failing to anticipate the cumbersome and complex nature of the reporting forms, which resulted in missed filing deadlines; and relying on inaccurate reporting advice from third parties. Understanding the problems and pitfalls employers faced last year and the lessons therefrom is key to helping clients avoid missteps when planning for 2016 information reporting.

Benefits counsel must also understand and advise employers of the new changes to the requirements for 2016 reporting, which represent a long-awaited expansion of the duties for mid-size and larger employers. Key to the new regime is that the standard for assessing penalties has become much stricter—there is no longer a “good faith effort” exception. Changes have also been made to Forms 1094-C and 1095-C.

Additionally, smaller employers are facing additional filing challenges, as reporting requirements expand and the phased implementation of the ACA continues. Further, employers must begin planning for the 40% surtax on “Cadillac” plans.

Listen as our authoritative panel reviews lessons and pitfalls from 2015 ACA information reporting and how to avoid similar problems with 2016 reporting. The panel will also discuss new changes that will impact 2016 reporting. The panel will offer planning techniques for both applicable large employers as well as small employers who are not subject to the employer mandate but may still have reporting obligations, and will outline the steps employers should take now to bring their plans into compliance with the ACA and avoid penalties.