MayReport - page 11

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MichaelW.
Jarrold-
Grapes, CFP
®
Kevin J.
Walsh,
CFP
®
Francis J.
Niehaus,
JD, CFP
®
Laura A.
Davitt
is enrolled in the employer’s self-insured
health plan, the employer must also give
the employee the Form 1095-C with
Parts I and III completed.
What Information Must Be
Repor ted on Form 1095-C?
Form 1095-C contains three parts.
In Part I, an employer will be re-
quired to identify the recipient of the
form and his employer.
In Part II, an employer will be re-
quired to use indicator codes to report
whether the employer offered affordable,
minimum value essential coverage to the
employee, his spouse, and/or his depen-
dents for each month of the year.
Note
: Part II communicates the ex-
tent to which an employer has satisfied its
obligation under the employer mandate,
so the accuracy of this Part will depend
upon an employer’s understanding of
the rules and regulations applicable
to the employer mandate. Failure to
understand those rules could lead to an
accuracy-related penalty for failure to
correctly complete Form 1095-C and/or
assessment of a penalty under Internal
Revenue Code Section 4980H.
In Part III, an employer who offers
self-insured health coverage must report
the months during which an individual
and each dependent was enrolled in
the self-insured health coverage. An
employer is not required to complete Part
III for an individual if the employer does
not offer self-insured health coverage or
if the individual was not enrolled in the
self-insured health coverage at any time
during the year.
What Should an Employer Be
Doing Now?
Applicable large employers should
be tracking data now to ensure that the
date can be accurately reported in 2016.
Additionally, employers should consider
whether they have the knowledge and
resources to prepare Forms 1095-C in
house or whether they should outsource
this function to a vendor. If using a
vendor, employers should be carefully
reviewing and negotiating service agree-
ments to ensure appropriate allocation of
responsibility and liability.
Wilcoxon is a partner inThompson Hine LLP’s
Employee Benefits and Executive Compensation
group and advises employers on the legal requirements
applicable to group health plans.
May 2015 CBA REPORT
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