b'Reporting Requirments Deadline Fast ApproachingH Paul Routh butemployerssponsoringself-fundedhealthplansareresponsible ealth care reform imposes new and complicated reporting requirements on (1) all large employers (i.e. those with 50 orfor paying the reinsurance fee.The fee is based on the number of more full-time and full-time equivalent employees) and (2)people participating in the self-funded health plan and there are a all size employers that sponsor self-funded health plans (i.e. even thosecouple of ways to come up with the count.The enrollment data has with fewer than 50 full-time and full-time equivalent employees).Theto be submitted to the government by November 15, 2015.The fee information is reported on IRS Form 1094 and IRS Form 1095.Thefor 2015 is $44 per person and the fee can be paid in two installments. information covers the 2015 calendar year (regardless of the plan year)The first installment is due January 15, 2016, and the second one is due and the IRS Form 1095 must be provided to the employees by JanuaryNovember 15, 2016.31, 2016.Additionally, both forms have to be submitted to the IRS byhttp://bit.ly/1MpIL2LFebruary 28, 2016 if the forms are submitted in paper format, and by March 31, 2016 if the forms are filed with the IRS electronically.Evenhttp://bit.ly/1YBMOj7though the employer mandate or play or pay rules have been postponedThese links provide information about how to determine the fee, for some employers, the reporting requirements have not been delayed.submit the data to the government and pay the reinsurance fee.The government has the following webpage to help employers complyMedicare Part D Notices Duewith the rules. Medicare Part D is the voluntary prescription drug program under http://1.usa.gov/1vstkT2 Medicare.There are two notice requirements under Medicare Part ThefollowingisagoodarticlethatexplainsthereportingD.The first notice goes to employees who are Medicare eligible.As requirements in detail.Note that there are special reporting rules fora practical matter, most employers simply provide the Medicare Part employers that contribute to multi-employer health plans. D notices to all employees.The government has provided templates http://bit.ly/1Psk6eo employers can use to comply with the notice requirements.The notices The IRS has indicated it will not assess penalties if the employer makesshould be distributed to the employees at the same time each year.The a good faith attempt to comply.However, the IRS also has indicatedsecond notice goes to the government and this is due within 60 days penalties will be assessed if the employer fails to complete the forms.Inof the start of each plan year.The notice to the government must be fact, the amounts of the potential penalties have just increased. submitted electronically.http://xerox.bz/1MXsK59 http://bit.ly/1Qy2PkdIn other words, no penalties will be assessed for the 2015 forms,http://go.cms.gov/YOWviXwhich are due early next year, if the employer makes a good faithThefirstlinkexplainsthenoticerequirementsandthesecond compliance effort.This means relief will be granted for incorrect orlinkisthegovernmentswebpageemployersshouldusetonotify incomplete information including missing social security numbers, butthegovernment.Althoughtherearenoautomaticpenaltiesfor not for failing to file and distribute the forms in a timely manner.So, itnot complying with the notice requirements, all employers should is critical the forms be filed on time. distribute the notices to employees and notify the government in a Getting Social Security Numbers timely manner.The previous article talks about the new reporting requirementsCadillac Tax is Comingunder health care reform.If you sponsor a self-funded health plan youOne of the more controversial provisions of health care reform is have to list all the people covered under the self-funded health planthe 40% non-deductible excise tax (i.e. the Cadillac tax) on the value PLUS their social security numbers.This should not be a big deal withofemployerprovidedhealthcoveragethatexceedscertaindollar respect to the employees but it could be challenging getting the socialamounts.The tax is scheduled to kick in January 1, 2018, regardless security numbers for the spouses and children.Employers have toof the employers plan year.The tax applies to all size employers make at least three attempts to get the social security numbers. and is projected to impact a significant number of employers.The http://bit.ly/1QZaA3o government continues to issue guidance on the tax.If the employer cannot get the social security numbers after threehttp://bit.ly/1VaaXbTattempts, the employer can list the persons date of birth on the forms.Although the tax does not become effective until 2018, it is not too Again, this option is only available after the employer has made threeearly to start thinking about it.Some people believe this provision will attempts to get the social security numbers.So if you sponsor abe repealed but health care reform is expensive and the Cadillac tax is self-funded health plan, check with your TPA now to see if they areone way to help pay for the law.gathering the social security numbers, and if they are not then you needDont Forget About Pregnancy Discrimination Lawsto start that process now.ACA Reinsurance Fee Coming Due Employerscontinuetoembracewellnessprogramsandthe Health care reform instituted a temporary reinsurance fee to helpgovernment continues to issue guidance.For example, the EEOC compensatethecarriersforhigh-riskclaimantsunderthehealthis taking an active role in this area.One popular tool is a health risk care exchanges or marketplaces.The reinsurance fee runs from 2014assessment where the person is asked to complete a health questionnaire. through 2016.The insurance company pays the fee with respect to fullyhttp://bit.ly/1JGEBDTinsured health plans (although the fees are built into the premiums),Employerscannotdiscriminatebasedonpregnancyandone employer ran afoul of the rules for firing an employee after the employer 12 www.mrca.orgMidwest Roofer'