How to Get Your Truck Drivers to Actually Use Your Wellness Program

wellnessTruck drivers have unique health concerns. An NIOSH survey found that 50% are smokers and 70% are obese. They’re prone to heart disease, diabetes, high blood pressure, kidney failure, back problems, and motor vehicle accidents related to fatigue and stress. These problems can lead to a loss of their Medical Examiner’s Certificate and their CDLs.

You want your staff to be healthy, comfortable, satisfied with their jobs, and working regularly, so you’ve implemented a company wellness program. The problem is… Your drivers aren’t using it.

That’s not unusual. 60% of employees don’t use wellness programs because they aren’t aware of it or the company culture doesn’t truly support the program. (Most drivers who use wellness programs are women.)

So how do you get your fleet of drivers to take advantage of your wellness program?

Step 1: Gather input from your drivers

Wellness programs with the best performance and highest adoption rates are ones that meet your employee’s needs. If none of your drivers smoke, a quit-smoking incentive won’t be very effective.

Talk to your drivers and ask what type of program would make their lives better. It could be challenging to query your entire crew if you don’t see them often, but it’s worth the effort.

Step 2: Reward drivers for healthy behavior

A proper wellness program addresses a few key areas of people’s health:

  • Diet – Your program should not only instruct your drivers how to choose healthy foods, but help them acquire those foods when they are on the road. It’s not easy to eat well when your options are limited.
  • Stress – Deadlines and traffic cause stress, which can affect the body. Educate your drivers on methods to relax, such as meditation and exercise.
  • Exercise – Build your drivers’ schedules so that they have time to get some simple exercise.
  • Avoiding bad behaviors – Risky behaviors like drug use and smoking have terrible effects on our health and ability to work. 54% of truckers are smokers, so this is an important area to address.
  • Hygiene – On the road, there aren’t many places to stop for proper body care. Coordinate your drivers’ routes so they have chances to stop at facilities with the right amenities.
  • Sleep – Chronic sleep deprivation affects your drivers’ ability to work, as well as their safety. Your wellness program should reward drivers for taking adequate sleep stops.

Many programs educate their staff about these health concerns, but they fail to go far enough. You need to actively incentive your employees to take part. Award bonuses for achieving health goals like losing weight or visiting the doctor.

If your drivers have any unique needs that learned from step one, make sure to include them in your program as well.

Step 3: Get executives and managers to participate in the program

Instead of paying lip-service to the program, managers and leaders within the organization should participate as well. If your wellness program encouraged weight loss, follow the plans advice to take off a few pounds yourself so your employees can see the benefits of the program and that you’ve implemented practical solutions.

Step 4: Create a communication strategy

Your drivers can’t make use of your program if they don’t know about it, but traditional methods of communication can be tough for on-the-road people you rarely see.

Make use of text messaging and radio messaging (via CB radios, not FM/AM channels). Create a company Facebook page or group. Stuff messaging into their check envelopes. If you have access to their vehicles, leave information on the seat so they can’t miss it.

Furthermore, enlist “cheerleaders” who actively encourages other employees to sign up for your wellness plan. Choose cheerleaders who work in various departments and levels in your company. They should approach other employees like them in terms of position and pay scale, so that everyone is recruited by a peer (people feel more comfortable with the program when they enroll with others like them). You might need to incentive these persons with commissions.

Finally, never give up

Don’t expect to achieve your program adoption number in the first week. Your employees need time to become aware of the program and commit to using it. Be positive, sell the benefits, and always be available for wellness counseling and enrollment.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Jill Goulet

Is Your Healthcare Plan Covering People It Shouldn’t?

healthcare eligibilityIf you provide an employer healthcare plan, it’s vital to ensure only the correct people are covered. Comprehensive healthcare insurance is one of the most important benefits you provide to employees, so keeping premiums down matters to everyone.

One of the main causes of rising premiums and healthcare costs is when ineligible people continue to be covered on a healthcare plan. For employer-provided health insurance, ineligible people are typically:

  • Former employees who have now left your business.
  • Employees whose status has changed, meaning they are no longer eligible under the plan, or should be on a different plan.
  • Dependents of an employee, where the status of the dependent has changed.

Examples of ineligible people for a healthcare plan

The following situations could all cause people to become ineligible.

  • A dependent child who ages beyond the dependent eligibility requirements in the plan.
  • A former spouse who separated from your employee.
  • An employee who leaves your business.
  • An employee whose status has changed, for example through changing the number of hours worked or moving to a different position, and whose new status requires a different healthcare plan.

Creating a healthcare eligibility audit

You need a process to understand and remove people from your employer-provided healthcare plan. Here’s how to put an “Employee and dependent healthcare eligibility audit” together.

Understand the eligibility requirements of your current employer-provided healthcare plans

Go through any existing employer-provided plans and note down:

  • All employees currently covered by the plan.
  • All dependents currently covered by the plan.
  • Eligibility requirements for employees.
  • Eligibility requirements for employee dependents.
  • Benefits and coverage provided.

You may hold this information internally, or you can get the data from your broker or healthcare insurance provider.

Analyze your existing employee data

Match your existing employee data against the healthcare plan eligibility requirements. Check:

  • Any employee listed as being on the plan is still employed by you.
  • Any dependent listed on the plan is still a dependent on the employee.
  • The type of healthcare plan is appropriate for the status of the employee.
  • All eligibility requirements are being met by any active plan participants.

Find gaps in the data

It’s likely that you will find gaps in the information. You may not have the latest details of dependents or employees. Complete a gap analysis to understand the data you need to ensure only appropriate people are covered by the plan.

Carry out a healthcare eligibility audit to close any gaps

Once you know what data you need, you will need to audit the information with your employees. Approach each employee with the details of their health insurance for them and their dependents and ask if all the information is factual and correct. If it is, get them to sign off on the information.

If the data is incorrect, get it updated and see how it affects healthcare eligibility. Communicate this back to the employee.

Careful communication is key

You will need to communicate carefully throughout this process. Employees may see the eligibility audit as a tool for taking away healthcare coverage. It’s important to manage the message carefully — The audit ensures only appropriate, eligible people are covered. That means less cost-leakage and medical expenses on plans, which keeps premiums down and ensures the right people have the right coverage.

You may want to complete the healthcare eligibility audit every year. This will ensure your records are up to date and reduce the premiums you and your employees need to spend.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

healthcare eligibility

Health Insurance and Large Groups — Understand How Your Premiums Are Calculated

?????????????????????????????????As an employer, one of the most valuable benefits you can offer to your employees is health insurance. For larger groups of 51 employees or more, you’ll likely have group health insurance coverage. This is a policy you’ll typically purchase from a broker (so you get the best deal) that you can then offer to all of your eligible employees. Around 98% of large employers (businesses with more than 200 employees) provide health coverage to some or all of their people.

These types of health insurance policies are great for your employees

Large group policies have several advantages over small group or individual health insurance plans:

  • The employer typically pays half or more of an employee’s premiums.
  • Premium only plans (POP) mean employees can pay premiums out of their pre-tax incomes.
  • This results in significantly subsidized premiums, meaning happier employees.
  • You get a healthier, better motivated workforce.

The health insurance cost is calculated slightly differently for large groups

The cost of large group policies is typically worked out when the employer decides to purchase, rather than being a fixed rate. The premiums, coverage, deductibles, and benefits are normally based on several factors:

  • The number of employees participating.
  • The type of coverage needed.
  • The amount of payments, deductibles, and benefits desired.
  • An employer’s prior claims history.

Individual employees don’t normally have to fill out health questionnaires, although employers may need to answer general questions on the health of their employees.

Other factors that can impact your health insurance premiums for large groups

Some insurers will also take the following into account:

  • The average age of the workforce.
  • Large claims that have been made by the employer previously.
  • The employer’s location — New York City is going to be more expensive than rural Wisconsin.
  • The gender makeup of the workforce.
  • The sector an employer works in — Premiums for constructions workers are going to be higher than for a retail shoe store.

All of these factors will feed into the calculations, coverage, benefits, and premiums.

Differences in health insurance premiums between small and large groups

If we look at a typical health insurance plan for a family, an employee will generally contribute:

  • In small groups — Around 35% of the premium.
  • In large groups — Around 25% of the premium.

There’s less of a burden on employees in large group health insurance plans.

If you’re a large employer, you must offer health insurance

The Affordable Care Act requires that employers of more than 50 people must offer affordable health plans to their ‘Full Time Equivalent” employees. The penalties for not providing this type of cover are:

  • Mandate Penalty — This comes into effect if an employer does not offer group health coverage. It’s calculated at $2,000 per employee, after the first 30 employees.
  • Qualification Penalty — This applies if an employer does not offer a “qualifying plan.” Qualifying plans must offer a certain minimum standard of coverage, and must be affordable to employees. The penalty is $3,000 per employee that does not get qualifying coverage and purchases a policy through the health insurance Marketplace.

The best way to make sure you get an affordable policy, and your employees get the coverage they need, is to use a specialist health insurance broker. They can help you navigate the complicated areas of health insurance and make sure you get the support you need to make the right choice.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Sinclair 7-22-15-14

Millennials and Healthcare — What Are They Looking For?

MillenialsAs the fastest-growing generational group, millennials (people born between the mid-1980s and the turn of the century) are a vital part of a strong workforce. If you want to attract millennials to your business, it’s important to understand what they need and more importantly, what they want.

In addition to a good salary and a positive work environment, the benefit millennials are most interested in is healthcare. In fact, since the Affordable Care Act came into force, the number of uninsured millennials has fallen from 23% to just 11%. Insured millennials are better for your business too — Insured millennials are more likely to report being in good or excellent health (79%) than uninsured millennials (62%).

With health insurance being front and center, and increasing options for employment, how do you attract and retain the best young talent? An important part is providing the right health benefits. Let’s explore a few options.

The health services millennials are most interested in

It’s important to provide health insurance plans to cover the main concerns millennials have about their health, this includes:

  • Accident and emergency coverage — Catastrophe can strike at any time. Millennials are less concerned with insurance against long-term, chronic illnesses than they are against accidents and other critical emergencies. A health plan that has good coverage for emergency room visits and treating acute conditions fits in well with their needs.
  • Doctor visits — Reasonable copay amounts for doctor and specialist visits rank highly with millennials.
  • Immunizations and wellness — Staying healthy is near the top of the millennial’s agenda. This includes vaccination for flu and human papillomavirus vaccine (HPV). wellness programs also play a part in helping to keep people healthy and reduce stress.
  • Alcohol and depression screening and counselling — Depression, anxiety and other mental illness affects a disproportionate number of young people. Access to therapy, treatment, and counsellors is critically important.
  • Sexual and reproductive health — Contraception, birth control, and sexual health are vital to millennials. Pregnancy, birth, breastfeeding support, and infant care are also high on the agenda for millennials wanting to start families.

 Keeping health premium costs down for millennials

Another important consideration is the cost of premiums, and the trend here is clear — Millennials much prefer low-premium, high-deductible health plans. For many millennials, cost is the most important factor when it comes to health insurance. In fact, two thirds of them said a premium of more than $200 a month is unaffordable. Clearly, with a premium that low, high-deductible plans are really the only choice.

Another option is to give millennials various options in terms of their overall benefits package — Perhaps they can trade off some vacation days for a lower insurance premium?

Addressing other health concerns

It’s not just premiums and coverage that are important to millennials. Many are concerned that being ill or injured for an extended period of time would mean they would get fired. Make sure you have clear employment policies in place that address these concerns — What are implications for someone’s employment if they are unable to work for the medium or long-term?

Another benefit you can offer is making it easier for millennials to transfer off of their family health plan. Children can stay on their parent’s plan until they’re 26 years old, so providing a convenient and easy way to switch will definitely help.

Make it clear that the Affordable Care Act requires everyone to be insured by law. Being uninsured just isn’t an option unless they want to pay yearly fines when they report their taxes. Clearly explain the benefits of health insurance and make it easy for people to start paying their premiums and enjoying their coverage.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Sinclair 7-22-15-14

Making Healthcare Hit Home — How to Explain Group Benefits to Your Employees

group benefitsGroup Benefits are both the most important and the most valued benefit provided by employers. American workers regularly cite healthcare as one of the main factors affecting their employment decisions – good or bad. A good group plan provides your people with peace of mind and helps them be happier and more confident in life and work.  In the end, it’s a game changer on many levels when it comes to employee retention and satisfaction.

It’s a shame then that so many people find health plans confusing — whether it’s benefits, coverage, deductibles, premiums, or copays, the bewildering number of choices makes it difficult for employees to make the right decision. Let’s face it – insurance is complicated.

Why is choosing health insurance difficult for employees?

There are many reasons for this including:

  • The sheer number of plans available.
  • The difference in benefits and coverage between plans.
  • Not understanding how premiums and out-of-pocket costs will affect finances.
  • Differences between in-network and out-of-network providers.
  • And many more areas…

 How to make the decision easier

There are several things you can do to make things easier for your team, they include:

Get your employees involved in choosing and educating about group benefits:

Get your managers and team leaders involved so they have a good understanding of all group benefit options and are comfortable discussing it with their direct reports. A great idea would be to create a Benefits Team within your organization. Here’s how: take one employee from each department and create a team. Involve them in the process of decision making when it comes to all areas of group benefit insurance. This way, if a change in benefits is necessary, employees are armed with the reasons why. They can educate others on their team and throughout the company. This helps ward off any negative discussions around changes that are going to happen with your company’s group benefit structure, whether it’s dental, medical, short term disability (STD), long term disability (LTD), etc. Ensure that group benefit insurance is presented both team or company meetings and via one-on-ones if needed.

 Provide a more limited number of health insurance plans

Research shows the more choice consumers are given, the more difficult it is to make the right choice. Think about providing five or six plans as “core” choices, but give employees the option to choose other types of plan if they need them.

Centralize all health insurance information in one place

Link to or create a good comparison of healthcare plans, that show benefits, co-pays, premiums, coverage, and other key elements side-by-side, so people can contrast and compare. Provide supporting material, examples, and context that discusses what the plans cover and how they would work in real life. Your health insurance provider or broker can help with this.

 Get your insurance broker to talk to your team

Your health insurance broker is an expert. Invite them to talk to your employees about the importance of making the right decision. Have them clearly explain the various options open to them and let your employees ask questions and share concerns.

Keep health insurance simple

Explain health coverage in simple terms. Have a person available – ideally your broker, who can answer questions from your team on the options open to them. Provide follow up information people can download and use to understand their coverage.

If you’re changing carriers, explain the reasons why

Sometimes you might need to change your insurance carrier. If you need to do this, provide very clear, simple explanations of how benefits and coverage are changing. Let people know exactly what benefits are being removed, what’s being gained, and any changes to existing benefits. If necessary, provide the reasoning behind changing insurers.

Above all, remember that health insurance is confusing to most people. Be completely transparent, provide simple, useful information, answer questions and ensure employees understand their responsibilities. Rely on your broker to help with the hard tasks – that’s what they are there for!

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Sinclair 7-22-15-14

Why medium-sized groups should steer clear of the Obamacare marketplace

affordable care actWhile the Affordable Care Act has helped over 20 million people get health insurance, it’s not always the best choice. Although it’s been a tremendous asset to millions of self-employed, part-time employees, and others who weren’t covered before, it’s not always right for employers. If you’re a medium-sized (or larger) employer or administering a medium-sized or bigger group, Obamacare isn’t for you. Here’s why.

An inconsistent approach to health plans

There are dozens of plans available on the ACA marketplace. Although this choice is a great thing for individuals, when it comes to understanding and implementing this across your business, it’s going to be an administrative nightmare.

There’s a huge variance in the types of plans, benefits, premiums, copays and deductibles offered by all the different plans and insurers. Combine this with confusion over networks and coverage, and your HR department will spend much of their time just trying to understand the myriad differences.

If you can offer your employees a simple and defined set of health insurance plans, it’s much easier for them to get the right information and understand all of the various benefits and payments they need to make for health insurance coverage. This means less confused, happier employees.

Obamacare may not offer the most cost effective plans

Premiums for ACA marketplace plans have been increasing year on year, and subsidies vary depending on an employee’s income. This combination of variable premiums and subsidies means an employee may not necessarily be getting the best deal through the open marketplace.

A dedicated health insurance broker can negotiate prices on health insurance plans on your behalf, and pass the cost savings onto you and your employees. If you’re employing more than a few employees, you can get good discounts for “economies of scale.”

You’ll lose your free health insurance broker

Don’t underestimate the value a good health insurance broker can provide. As experts in health insurance they can:

  • Provide helpful information to you and your employees.
  • Answer any questions about health insurance, premiums, and coverage.
  • Work closely with your HR department to give employees the information they need.
  • Negotiate better prices with insurers on your behalf.

Increased worry and confusion among your employees

No one wants to spend too long worrying about their health plan. Most people just want to know they’re properly covered, that their premiums are reasonable, and that their health will be taken care of. When you offer a clear and defined set of health insurance plans, that makes things easier for everyone. The combination of a single point of contact in HR, proper information about health insurance, and support from a broker, gives your employees the confidence they need.

As you can see, the combination of a simple and consistent approach to health insurance is better for you and your people. When you combine that with better pricing, expert support, less administration, and more confident employees, it just makes sense to talk to your health insurance broker. They’ll help you decide which plans are best for your people, and give you the service and expertise you and they need to make an informed choice.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Sinclair 7-22-15-14

 

Changes from the Affordable Care Act in 2017 — What you need to know

Doctor Tablet Computer Affordable Care ActThe Affordable Care Act is making some changes in 2017 and if you’re providing health insurance via a group plan you need to make sure you’re compliant. Here’s a quick guide to the main changes and what you need to do to ensure you meet all the new guidelines and regulations.

Remember, we’re here to help, so if you have any questions about any of this, please do get in touch. The main changes include:

  • Grandfathered plans — Check your plan is still grandfathered.
  • Deductibles amounts — Changing deductibles for EHB and HSA plans.
  • Employee contributions — Changes to FSB contribution limits from employees.
  • Group plan information — Changes to how information on group benefits and coverage is provided to employees.
  • Reinsurance — No reinsurance fees for self-funded plans in 2017.
  • Large employers — Must offer health plans if you have more than 50 full-time employees.

Grandfathered plans — Check grandfathered status for 2017

You likely have a “grandfathered plan” if the plan was already in existence when the ACA came into effect in March 2010 and it hasn’t had significant changes since then. Grandfathered plans can retain their old benefits, premiums, and other features and fees so long as they don’t have prohibited changes made.

  • If your plan has been grandfathered, check that there aren’t any changes being made that will make it lose the grandfathered status in 2017.
  • If it does lose grandfathered status, you’ll need to ensure it meets all of the regulations and guidelines that the ACA requires.

Essential Health Benefits (EHB) and Health Savings Accounts (HSA)  High Deductibles plans — Amounts changing in 2017

Under the ACA, the Out of Pocket maximum fee for EHBs can’t exceed $7,150 for self-only coverage and $14,300 for family coverage in 2017.

  • Check your plan’s out of pocket maximums to make sure it complies with these guidelines.
  • If you have a Health Savings Account (HSA) plan with high deductibles, make sure those deductibles are below the ACAs allowed limits. In 2017 that’s $6,550 for self-only and $13,100 for families.

Health Flexible Spending Account (FSA) contributions changing in 2017

The amount an employee can contribute, pre-tax, to a health spending account was $2,550 in 2016 and may be increased in 2017. Note that this amount does not apply to employer contributions or to contributions to other benefits such as dependent care assistance.

  • Check to see what the new FSA limit is in 2017, it’s normally announced at the end of the year.
  • If you aren’t able to get that information, use the 2016 limit of $2,550.

Summary of benefits and coverage (SBC) information needs to be updated

The ACA has strict guidelines on how information on benefits and coverage is provided to plan members. In 2017, these guidelines are changing, and a new template will be introduced for SBC information.

  • Use the new SBC template for open-enrollment plans or plans starting on or after April 1 2017.

Reinsurance fees in 2017 — Applies if you are a self-funded plan

From 2014 through 2016, self-funded plans needed to pay fees to a transitional reinsurance program. Starting in 2017, reinsurance fees no longer apply, although your 2016 fees will be due in 2017.

  • Submit the 2016 reinsurance form and make the appropriate payments for the 2016 benefit year.

Applicable Large Employers (ALE) will be subject to penalties if they do not provide appropriate insurance coverage to full-time employees

ALEs must offer affordable health coverage to their full-time employees. They will be penalized if any full-time employee receives a subsidy for health coverage through an Exchange.

  • Calculate the number of Full Time Equivalent (FTE) employees — These are individuals working, on average, more than 30 hours a week or 130 hours a month. If you have more than 50, you are likely an ALE.
  • Ensure that you have proper health care coverage in place for your full time employees in 2017.
  • Report the coverage to your employees and the IRS.

If you’ve got any questions about how this affects you, we’re only a phone call away. We’ve got the experience and expertise to talk you through any changes you need to make.

Jill Goulet
Risk Management Consultant
jgoulet@srfm.com

Sinclair 7-22-15-14

2015 Draft Instructions for 6055 and 6056 Reporting Include Filing Extensions

Sinclair 7-22-15-21The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) or provide to their employees. Reporting is first required in 2016, related to coverage offered or provided in 2015.

 

On Aug. 7, 2015, the Internal Revenue Service (IRS) released the following:

2015 draft Forms 1094-B, 1095-B, 1094-C and 1095-C were previously released on June 16, 2015. Except for a few minor changes and a number of clarifications, the 2015 draft forms and instructions are largely unchanged from the 2014 versions. However, the 2015 draft instructions also include:

  •  A proposed automatic 30-day filing extension, upon request (under certain hardship conditions, reporting entities may apply for an additional 30-day extension); and
  •  A proposed waiver from the requirement to file returns electronically.

These 2015 forms and instructions are draft versions only and should not be filed with the IRS or relied upon for filing. The IRS may make changes prior to releasing final 2015 versions.

Proposed Filing Extensions and Waivers Although the changes made in the 2015 draft instructions were mostly clarifications of existing requirements, they did include new proposed filing extensions and a proposed waiver from the requirement to file electronically.

Filing Extensions Reporting entities can get an automatic 30-day extension of time to file by completing and filing Form 8809, Application for Extension of Time To File Information Returns by the due date of the returns. The form may be submitted on paper or electronically through the FIRE System. No signature or explanation is required for the extension.

Under certain hardship conditions, reporting entities may apply for an additional 30-day extension. See the instructions for Form 8809 for more information.

Furnishing Extensions Reporting entities may also request an extension of time to furnish the statements to recipients by sending a letter to: IRS, Information Returns Branch, Attn: Extension of Time Coordinator, 240 Murall Drive, Mail Stop 4360, Kearneysville, WV 25430.

The letter must include the filer’s name, taxpayer identification number (TIN) and address, the type of return, a statement that the extension request is for providing statements to recipients, a reason for the delay and the signature of the filer or authorized agent. The request must be postmarked by the date on which the statements are due to the recipients.

If a request for an extension is approved, a maximum of 30 extra days will generally be granted to furnish the recipient statements.

Electronic Reporting Waiver To receive a waiver from the requirement to file returns electronically, reporting entities must submit Form 8508, Request for Waiver From Filing Information Returns Electronically, at least 45 days before the due date of the returns.

Without an approved waiver, a reporting entity that is required to file electronically but fails to do so may be subject to a penalty of up to $250 per return, unless it can establish reasonable cause. However, reporting entities can file up to 250 returns on paper; those returns will not be subject to a penalty for failure to file electronically.

2015 Draft Instructions—Additional Clarifications 

The 2015 draft instructions also include the following clarifications:

  • Substitute Forms—Entities using substitute forms instead of the official IRS versions may develop substitute forms themselves or buy them from a private printer. Currently in draft form, Publication 5223, General Rules & Specifications for Substitute ACA Forms 1094-B, 1095-B, 1094-C, and 1095-C and Certain Other Information, explains the requirements for the format and content of substitute statements to recipients. Only forms that conform to the official form and the specifications in Publication 5223 are acceptable for filing with the IRS.
  • Corrected Returns—The 2015 draft instructions include detailed information for correcting returns. The procedure for correcting a return will vary, depending on the form and whether it is filed with the IRS or provided to individuals. The instructions provide examples of errors and step-by-step instructions for filing corrected returns.
  • Expatriate Health Plans—According to the 2015 draft instructions, statements reporting coverage under an expatriate health plan may generally be furnished electronically without affirmative consent, unless the recipient affirmatively refuses consent or requests a paper statement. For more information on expatriate health plans, see Notice 2015-43.
  • Penalties—The 2015 draft instructions include an additional section outlining the penalties for reporting entities that fail to comply with the reporting requirements. For 2015, the IRS will not impose penalties for reporting incorrect or incomplete information if the filer can show that it made good faith efforts to comply with the information reporting requirements. No relief is provided for reporting entities that fail to file on time. For more information on penalty relief, see the Sections 6055 and 6056 FAQs.
  • Multiemployer Interim Rule Relief—For reporting offers of coverage on the Form 1095-C for 2015, an employer relying on the multiemployer arrangement interim guidance should enter Code 1H on line 14 for any month for which the employer enters Code 2E on line 16 (indicating that the employer was required to contribute to a multiemployer plan on behalf of the employee for that month and therefore is eligible for multiemployer interim rule relief). For reporting for 2015, Code 1H may be entered without regard to whether the employee was eligible to enroll in coverage under the multiemployer plan. For 2016 and future years, reporting for offers of coverage made through a multiemployer plan may be reported in a different manner.
  • COBRA Coverage—For purposes of the Form 1095-C, the 2015 draft instructions included additional information for reporting offers of COBRA coverage. In general, an offer of COBRA coverage to a former employee upon termination is reported as an offer of coverage on Line 14 only if the former employee enrolls in the coverage. An offer of COBRA coverage to an active employee (for example, due to a reduction in the employee’s hours) is reported in the same manner and uses the same code as an offer of that type of coverage to any other active employee.
  • Method for Determining Monthly Cost—For purposes of the Form 1095-C, the 2015 draft instructions allow an employer to divide the total employee share of the premium for the plan year by the number of months in the plan year to determine the monthly employee contribution for the plan year. This monthly employee contribution would then be reported for any months of that plan year that fall in the 2015 calendar year.
  • Indexed Affordability Percentage—The 2015 draft instructions note that references to 9.5 percent in the affordability safe harbors and alternative reporting methods may be subject to change if future IRS guidance provides that the percentage is indexed in the same manner as for purposes of applying the affordability thresholds under the premium tax credit. In general, this should not affect reporting for 2015, but taxpayers may visit www.IRS.gov for any related updates.
  • Minimum Value—The definition of “minimum value” was revised to clarify that the plan must provide substantial coverage of inpatient hospitalization services and physician services. An offer of coverage under a plan that fails to provide substantial coverage of inpatient hospitalization and physician services should be reported on Form 1095-C as not providing minimum value, even if an employer qualifies for the transition rule under Notice 2014-69.
  • Supplemental Coverage—The 2015 draft instructions for Forms 1094-B and 1095-B included information about supplemental coverage. Providers are not required to report the following minimum essential coverage that is supplemental to other minimum essential coverage:
    •  Coverage that supplements a government-sponsored program, such as Medicare or TRICARE supplemental coverage.
    •  Coverage of an individual in more than one plan or program provided by the same plan sponsor (the plan sponsor is required to report only one type of minimum essential coverage).

According to the 2015 draft instructions, coverage isn’t provided by the same plan sponsor if they aren’t reported by the same reporting entity. Thus, an insured group health plan and a self-insured health reimbursement arrangement covering the employees of the same employer aren’t supplemental.

2015 Draft Forms

The 2015 draft forms were largely unchanged from the 2014 versions. One change was addressed in the 2015 draft instructions.

The 2015 draft Form 1095-C includes an additional field, titled “Plan Start Month.” This new field is optional for 2015, but will be required for 2016 and beyond. For 2015, ALEs can choose to:

    •  Add this field and provide plan year information;
    •  Add this field and enter “00”; or
    •  Leave this new field out (thus using the 2014 format).

Additional Resources

The IRS previously released the following final 2014 versions on Feb. 8, 2015:

These forms are not required to be filed for 2014, but reporting entities may voluntarily file them in 2015 for 2014 coverage.

The IRS also released:

Jill Goulet

Benefits Risk Manager – Sinclair Risk & Financial Management

jgoulet@srfm.com