We want to provide a friendly reminder that many of the provisions within the Affordable Care Act (ACA) go into effect starting in 2015 with additional provisions beginning in 2016. The following is a brief summary of some of the more important points:
The applicable large employer (ALE) mandate does not apply to employers with fewer than 50 full-time equivalent (FTE) employees (be careful, however, if you have entities related through common ownership as they may need to be aggregated). For 2015, there is transitional relief for employers with 50-99 FTEs.
The calculation of the number of employees for the ALE mandate includes part-time and seasonal workers by adjusting their hours to a full-time equivalent based on a prescribed formula in the ACA. Additionally, the calculation on the number of FTEs is to be done monthly.
Depending on the type of insurance arrangement you have and whether you are an ALE, you may be required to provide certain documentation (Form 1095-B or 1095-C) to your employees regarding health care coverage.
Multiple layers of potential penalties exist and can be substantial.
Significant penalties exist for any employer with two or more employees that does not offer coverage but reimburses health insurance premiums or costs through an HRA, FSA or EPP.
We recommend consulting with your insurance agent if you have not already done so to ensure you are ACA compliant or to minimize your potential exposure to penalties. We also recommend consulting with your payroll service provider to ensure that you are meeting any reporting requirements.
