Since we know you love regulations and IRS filings so much, we know you’re getting closer to completing what is due on April 2nd. For a final run down, please see below.
- Consolidated, Aggregated and Validated HR, Time & Attendance, Payroll. and Health Benefits data for each month of 2017.This is an important step to ensuring an accurate and timely ACA filing with the IRS. Transition relief for ALEs is not available for 2017 as it was for the 2015 and 2016 tax reporting years. The unavailability of transition good faith relief for 2017 onward makes the use of accurate data in ACA compliance filings with the IRS even more critical than ever for the 2017 tax reporting year.
- Conducted a monthly audit of employment classifications, such as full-time, part time, variable and seasonal.The ACA employer mandate requires employers to accurately identify their full-time employees (and their dependents) and offer them minimum essential coverage. A 5% margin of error is allowed each month. For any month that an employer strays outside of the 5% margin of error in 2017, the employer is exposed to an annualized penalty of $2,260 multiplied by the number of full-time employees. If you have not been conducting these monthly audits, you may want to recheck your information to be sure of its accuracy before completing your filing with the IRS.
- Determined your Workforce Composition, at both the ‘Aggregated Employer Group’ and EIN level.This includes knowing the numbers of full-time and part-time employees, including full-time employees that are not part of the limited non-assessment period. You also need to know the numbers of “pending” and “trending” employees when using the Look-Back Measurement Method. Remember to reconcile historical full-time employees, “not in Limited Non-Assessment Period,” without an offer of health coverage. For instance, if you own or are a partner of several business organizations, each with less than 50 employees, you still may be required to file ACA information with the IRS as a Controlled Group under ACA employer aggregation rules.
- Calculated health coverage affordability.For 2017, in order to meet the ACA’s affordability threshold, the employee’s required contribution to the lowest cost monthly premium for Self-Only coverage providing Minimum Value should generally not exceed 9.69% of either (a) the employee’s Rate of Pay, (b) the employee’s W-2 Box 1 wages, or (c) the Federal Poverty Line threshold for a household of 1. If you have not done those calculations, it might be worth a spot check to see where you stand. When calculating affordability, make sure to account for flex credits through cafeteria plans as allowed under IRS Section 125, and other factors such as opt-out payments, wellness plans, HRAs and fringe benefits.
- Checked the accuracy of your data.Many of the problems encountered on the path to ACA compliance are data problems. Make sure your key data points are accurate, including:
- Legal Name
- Employment Periods, including hiring and termination dates
- Rate of Pay
- Compensation Type
- Employee Class
- Health Benefits Class
- Health Benefits Eligibility Periods
- Health Benefits Enrollment Periods
- W-2 information
We are working hard to ensure you are in the know about all the rules and regulations coming out of Washington D.C. However, if you have questions please contact the NARFA Team at any time, and we are always happy to help.
If you are not a member, please visit the NARFA website to learn more about our employee benefit programs and why our powerful Association continues to provide strength and stability for our members year after year. It is time to experience NARFA “power in numbers.”
Thanks to our friends at ACA Times for some content in this article.