|Employer Checklist for period ending December 31, 2015|
1. Comply with the Employer Shared Responsibility ("Pay or Play") requirements: Employers with greater than 50 full-time employees (including full-time equivalents) must comply with "Pay or Play" no later than January 1, 2016. "Pay or Play" requirements write that an employer must provide "affordable" coverage that provides "minimum value" to full-time employees and their dependents, or else pay the I.R.S. a penalty should one full-time employee receive a premium tax credit. The "Pay or Play" I.R.S. published Q&A is attached for reference at http://www.irs.gov/Affordable-Care-Act/Employers/Employer-Shared-Responsibility-Provisions. Stay tuned for more information in the coming months from PHBP, and be sure to contact legal counsel and/or your tax advisor for additional questions.
2. Section 6056 of the I.R.C. requires large employers (50 full-time employees, including full-time equivalents) to report information about compliance with the Employer Shared Responsibility ("Pay or Play") provisions and to furnish related statements to their employees to help employees determine whether, for each month of the calendar year, they can claim a premium tax credit on their tax returns. Forms to file are:
a. A separate Form 1095-C for each of an employer's full-time employees; and
b. A transmittal on Form 1094-C for all of the returns filed for a given calendar year.
Please stay tuned for more information in the coming months from PHBP, and be sure to contact your tax advisor with any questions about completing these forms.
3. Be aware of any PHBP emails and other correspondence sent to you with regard to "Open Enrollment". We're providing subsidized freelancer dependent coverage, and for out staff employer, rate increases that are more than competitive with the current small group plan marketplace. Enrollment forms and an updated Participation Agreement have been sent to you, and will require your signature. In addition, employee election forms for any employee with a change in election will need to be submitted by end of year as well.
4. We've updated our Participation Agreement to provide greater clarity around the definition of Gross Earnings. Gross Earnings are any earning reported on a freelancer's W2, so this amount includes bonuses and cancellation fees.