We thought you might benefit from reviewing a few key questions and answers generated during the recent ACA Compliance Information Webinar:
Q: Since Kentucky self-insures its government employees (including school districts), will the school districts still need to submit the IRS reports and employee statements for ACA Compliance?
A: Yes, KY districts are the employers and will need to submit those reports. The KY Department of Insurance may provide the dependents and offer codes via files imported into Munis.
Q: Will school districts check “yes” or ‘no” for 1094 C, line 21 regarding whether the employer is a member of an aggregated ALE group?
A: The district will likely check the “No” box because the school district is not an aggregated employer.
Q: Will the school districts in Kentucky file the 1095’s for Kentucky retirees?
A: If the retiree worked for any month of the 2015 year, then the school district would report the retiree as a full-time employee with a 1095c up to the retirement month. However… it is uncertain if or how the Kentucky Teacher Retirement System (KTRS) would pass data into MUNIS to report on retirees who were in retirement status all 12 months of 2015.
Q: What is the amount to be entered into Line 15 of the 1095 C? The amount that the employee pays or the amount of the lowest premium cost for self-only minimum value coverage?
A: The IRS instructions say that it’s the amount of the lowest premium cost for self-only minimum value coverage. The PSST interpretation is that this will generally be the lowest “employee only bronze plan”. PSST believes that for most school districts, there is one cost for all employees.
Q: What would be the code if a new employee was offered coverage during his/her waiting (non-assessment) period?
A: If coverage was offered during a non-assessment period, then the form 1095C should reflect that. Line 14’s Indicator Code would reflect offering the coverage, and line 16’s indicator code would reflect 2D – non-assessment period. The important factor is that the coverage was offered, and district rules may allow coverage during non-assessment periods.
Q: Does an employer get automatic notification when an employee is approved for a premium tax credit? If so, must the employer register to receive these notifications of premium tax credit approvals?
A: In its research, PSST staff could not find notifications from the federal government or exchange to the employer. Our research indicates that it is the IRS who will match 1095 data to the exchange data, and then follow an action course based upon the results. There was a finding in Washington State that the state exchange is sending letters when someone signs up and receives a premium tax credit or subsidy, informing the employer they own a fine if they do not prove that employee is not qualified. For further information, a search for ”how the Marketplace confirms premium tax credits” will result in several authorized agencies with articles containing valuable consumer information.
