March 2015 HR Alert | Employers Prepare for 2015 ACA Reporting Requirements
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White House Announces Proposed Retirement Reforms

In Earlier this year, the White House announced several retirement tax reform initiatives that are intended to expand access to retirement savings options. The retirement tax reform plan includes the following proposals:
  • Require Automatic Enrollment for Those Without Access to a Retirement Plan. Under this proposal, every employer  that has been in business for at least two years with more than 10 employees that does not currently offer a retirement plan would be required to enroll their workers in an IRA (“Auto-IRA”).
  • Provide Tax Savings for Auto-IRA adoption. This proposal would provide any employer with 100 or fewer employees who offers an Auto-IRA a $3,000 ($1,000 per year for three years) tax credit. Additionally, small employers who newly offer a retirement plan would receive a $4,500 ($1,500 per year for three years) tax credit to help them offset administrative expenses. Small employers who already offer a plan and add auto-enrollment would receive an additional $1,500 ($250 per year for six years) tax credit. 
  • Expand Retirement Plan Access to Part-Time Workers. Generally, employers offering retirement plans are allowed to exclude employees who work less than 1,000 hours per year (regardless of how long they have worked for the employer). Under this proposal, employers who offer retirement plans would be required to allow part-time workers, who have worked for the employer for at least 500 hours per year for three years or more, to make voluntary contributions to the plan. 
  • Cap Balances on Tax-Preferred Retirement Plans. This proposal would prohibit contributions to and accruals of additional benefits in tax-preferred retirement plans and IRAs once balances reach $3.4 million.

Listen to the Interview with Anne Tyler Hall (formerly Hamby) on Atlanta Legal Experts, Buckhead Business Radio X (January 27, 2015)


This HR Alert is intended to provide a summary of significant developments to clients and friends. It is intended to be informational only and does not constitute legal advice regarding any specific situation. This material may also be considered attorney advertising under certain jurisdictions.



HR Alert

March 2015

Last month, the Internal Revenue Service (IRS) finalized forms and instructions for employer reporting requirements under the Affordable Care Act (ACA) that take effect in 2015. The forms are intended to be used to fulfill the requirements for reporting minimum essential coverage (MEC) requirements under Internal Revenue Code ("Code") Section 6055 and the details of health coverage (if any) offered to full-time employees under Code Section 6056. The reporting requirements are effective for 2015 with the first required reporting due in 2016.  

Employer Reporting Requirements for Self and Fully Insured Health Plans
An employer with a self-insured plan can report using a single, consolidated form that includes information required under both Code Sections 6055 and 6056. The combined form has two sections: the top half includes the information necessary for Code Section 6056 reporting and the bottom half includes information necessary to satisfy Code Section 6055. An employer with a fully insured health plan is required to complete only the top section of the combined form (reporting for Code Section 6056). Insurers and other providers of health coverage will report only under Code Section 6055, using a separate form.

The following information must be included for Code Section 6055 reporting purposes:
  • Name, address, and taxpayer identification number of (TIN) of the reporting entity required to file the return;
  • Name, address, and TIN of each individual (including spouses and dependents) covered under the plan; and
  • For each covered individual, the months in which (for at least one day) the individual was enrolled in coverage.
The following information must be included for Code Section 6056 reporting purposes:
  • Employer name, address, and TIN;
  • Name and phone number of employer’s contact person;
  • Calendar year for which the information is reported;
  • Whether the applicable large employer provided minimum essential coverage (MEC) to full-time employees and their dependents;
  • Months minimum essential coverage was available;
  • Each full-time employee’s monthly cost for employee-only coverage under the employer’s minimum value plan;
  • Number of full-time employees for each month; and
  • Name, address, and TIN of each full-time employee during the year and the months the employee was covered.
IRS Forms 1094-B and 1095-B are necessary to fulfill the requirements under Code Section 6055. IRS Forms 1094-C and 1095-C are to be used to satisfy the requirements under Code Section 6056.

Timing of Filing
Annual employer returns must be filed with the IRS by February 28 (March 31, if filed electronically). The report will include plan and employee information for the prior calendar year regardless of the employer’s plan year. Corresponding employee statements must be provided annually to full-time employees by January 31. 

We Changed Our Name and Moved! 

Hall Benefits Law
Anne Tyler Hall
ERISA & Benefits Attorney
3355 Lenox Road
Suite 750
Atlanta, GA 30326
(678) 439-6236 (office)

Copyright © 2015 Hall Benefits Law, All rights reserved.

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