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2017 ACA Updates and Compliance Tips

Deadlines for 2017 Forms

2017 Forms 1095-C must be distributed to full-time employees on or before January 31, 2018. 2017 Forms 1094-C and 1095-C must be filed with IRS by February 28, 2018 if filing on paper or by April 2, 2018 if filing electronically.

Coverage for Dependents

Beginning in 2016 (or plan years that begin in 2016), an ALE Member is required to offer minimum essential coverage to its full-time employees’ dependents as well as to the full-time employees.

95% Offer Requirement

Each calendar month, an ALE member must offer MEC to at least 95% of its full-time employees and their dependents (or all but five full-time employees and their dependents if there are fewer than 100 full-time employees that month).

Document All Offers of Coverage For Each Benefit Plan Year

ALE members should have a signed and dated form from each employee to whom coverage was offered for each health plan year. The form should: 1) indicate the effective date for the coverage offered (i.e., when would the coverage be effective if the employee chooses to enroll), 2) clearly indicate whether or not the employee is choosing to enroll in the coverage and 3) include the date that the employee executed the form to elect or decline the coverage offered.

Identify Full-Time Employees

Employees designated as full-time at their hire date (reasonably expected to average at least 30 hours of service per week) must be offered an opportunity to enroll in MEC no later than the first day of the fourth full calendar month of employment.

1,560 hours of service or more by variable hour employees during their initial measurement period or during the standard measurement period means that the employee is full-time and must be offered the opportunity to enroll in MEC within the specified period after their hire date or during open enrollment, as applicable.

Marketplace Notices

In 2017, the Department of Health and Human Services started sending letters to employers of individuals who have been determined eligible for advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs) for at least one month during 2016 to help pay for Marketplace coverage and who have enrolled in coverage through the Marketplace.

Employers have 90 days from the date of the notice to request an appeal from the Marketplace if they feel that the APTC or CSR was provided to the employee in error. Employers have an opportunity to request review of relevant evidence used to determine the employee’s eligibility for APTC or CSRs including information regarding whether the employee’s income is above or below the threshold for affordability of employer-sponsored MEC.

Appeals can be filed on this form. We can assist you with preparation of this appeal form and to request the evidence used to determine the employee’s eligibility for subsidy.