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ACA Best Practices: Annual Reporting and the “Cadillac” Excise Tax

2015-03-17 11:00:00

Just as Applicable Large Employers (ALEs) have gotten through annual enrollment and the ACA’s Employer Shared Responsibility provisions have become effective, they must now look forward to additional and challenging requirements still to come.Beginning in 2016, ALEs will have to begin filing annual information reports with the IRS documenting that they have complied with Section 4980H of the Internal Revenue Code.The data elements required for this purpose are many and must be stored and maintained by the employer – employers are subject to audit by the IRS, and this data will be critical in disputing incorrect penalty assessments under the ACA. Without this data, employers could find themselves exposed to substantial financial penalties reaching hundreds of thousands or even million dollars in fines and this is only the NEXT step in addressing requirements under the ACA. Beginning in 2016, “Auto-Enrollment” requirements may be enacted, along with non-discrimination requirements for fully insured plans.In 2018 the “Cadillac” Excise Tax on high cost health plans will take effect – with the potential for significant non-deductible tax penalties. (The Congressional Budget Office has estimated that this provision alone will result in $120 Billion in new tax payments between 2018 and 2024). The time to develop a strategy to minimize or avoid such taxes is NOW.Please join us for our next in a series of ACA Best Practices webcasts in which we’ll provide actionable insights how best to comply with ongoing ACA requirements. During this webcast, we’ll address the following:

Reporting on the 1094-C and 1095-C
1.       Who needs to report?
2.       Who needs to get a report?
3.       When do reports have to be filed?
4.       Penalties for late filings and/or incorrect filings
5.       Section 4980H Penalty Assessments, Reconciliation and Appeals

Types and Sources of Data Required to Comply
What will the required documentation for reporting and potential audit look like?

The Cadillac Excise Tax
1.       What is it?
2.       Why is it part of the ACA?
3.       Is it here to stay?
4.       What impact this will have on plan designs?
5.       What can employers do to reduce or eliminate their exposure to this tax?

ADP’s experts remain at the forefront of helping employers understand the complex compliance, financial, and strategic issues surrounding workforce management.

The content presented during this webcast should not be construed as legal advice. ADP encourages you to consult with appropriate counsel.

Who Should Participate
Executive Management, Finance Managers and CFOs, Benefits/HR Leadership and Business Owners as well as all HR Professionals.
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Recommended Resources
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During this webcast, we’ll address the following:

  • Reporting on the 1094-C and 1095-C –
    1. Who needs to report?
    2. Who needs to get a report?
    3. When do reports have to be filed?
    4. Penalties for late filings and/or incorrect filings
    5. Section 4980H Penalty Assessments, Reconciliation and Appeals
  • Types and Sources of Data Required to Comply- What will the required documentation for reporting and potential audit look like?
  • The Cadillac Excise Tax
    1. What is it?
    2. Why is it part of the ACA?
    3. Is it here to stay?
    4. What impact this will have on plan designs?
    5. What can employers do to reduce or eliminate their exposure to this tax?

haslinger160John Haslinger
Vice President of Benefits Outsourcing Consulting
ADP

John is Vice President of ADP Benefits Outsourcing Consulting, responsible for Compliance and Health Care. He has 35 years of experience in the areas of employee benefits, spanning strategic design, compliance and administration for both retirement and H&W benefit plans. In particular, his experience has focused on operations, outsourcing and shared service environments. Prior to joining ADP, John was a Director in Deloitte Consulting’s Human Capital Practice where he consulted with both plan sponsors and providers in these areas – addressing strategic, operational, and funding issues.

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