Compliance Calendar 2015

 

The following are important compliance due dates and reminders for 2015. The laws and due dates apply based on the number of employees, whether or not someone does business with the Government, and on benefits offered. Other state-by-state laws may also apply.

1/1/2015 - Minimum Wage changes: Although no federal minimum wage increase goes into effect, many states and/or cities may have a scheduled minimum wage increase. Jan. 2015 state minimum wage increases include: Alaska $8.75, Arizona $8.05, Arkansas $7.50, Connecticut $9.15, Florida $8.05, Hawaii $7.75, Massachusetts $9.00, Missouri $7.65, Montana $8.05, Nebraska $8.00, New Jersey $8.38, New York $8.75, Ohio $8.10, Oregon $9.25, Rhode Island $9.00, South Dakota $8.50, Vermont $9.15, Washington $9.47, West Virginia $8.00

1/1/2015 - Social Security Taxable Limit Increases: The maximum amount of earnings subject to the Social Security tax (taxable maximum) has been increased for 2015 to $118,500 from $117,000.

1/1/2015 – Retirement Plan Limits: The Internal Revenue Service has adjusted retirement plan limits. If you offer a retirement plan, verify and update your limits.

1/1/2015 – W-2 Reporting of Health Benefits: Employers who issue 250 or more W-2 for the year must continue to track and report premiums paid by the employer on W-2s for health plans. Employers are not required to report contributions for Health FSA, HRA, dental or vision, HAS and Archer MSA, long-term care, on-site medical clinics, church plans or governmental plans.

1/1/2015 – ACA Reporting Provisions go into Effect: Reporting provisions under tax code sections 6055 and 6056 go into effect. Employers must compile monthly and report annually numerous data points to the IRS and their own employees. This data will be used to verify the individual and employer mandates under the law.

Although required reporting under sections 6055 and 6056 will not occur until January 2016 to employees and March 2016 to the IRS, the data being reported is based on what happened during 2015.

1/1/2015 – Flexible Spending Account Limits and Extensions: The employee health flexible spending account (FSA) contribution limit has been increased to $2,550 for 2015, and remains at $5,000 annually for dependent care FSA contributions. A new provision allows plans to offer a $500 health FSA carryover of unused amounts for the next plan year, providing the plan documents are amended and employees are notified prior to the beginning of the plan year. Alternatively, plans can offer a 2.5 month grace period for health and dependent care FSAs, again providing plan documents reflect this grace period and employees are notified.

1/1/2015 – Health Savings Account and High-Deductible Health Plan Limits: Health Savings Account (HSA) and High-Deductible Health Plan (HDHP) limits have been increased for 2015.

  • The HSA annual contribution maximums increase to $3,350 for individual and $6,650 for family coverage.
  • For HSA-compatible HDHPs, the annual out-of-pocket spending limits are $6,450 (individual) and $12,900 (family). The HDHP minimum deductible increases to $1,300 for individual and $2,600 for family coverage.
  • HSA age 55 catch-up contributions stay at $1,000.

 

1/1/2015 – Retirement Plan Limits: The Internal Revenue Service has adjusted retirement plan limits. If you offer a retirement plan, verify and update your limits.

1/31/2015 – W-2 Employee Reports Due: Employers must provide all employees copies of Form W-2 reporting earnings and taxes for 2014 by January 31, 2015.

2/1/2015 – OSHA Form 300 A Accident Summary Posting: Employers must post OSHA Form 300A Accident Summary in a public area from February 1 through April 30 for previous year’s accidents (repeat annually).

2/15/2015 – Federal Market Place – Open Enrollment Ends: Individuals can enroll until February 15, 2015. After that, they can’t get 2015 coverage unless they qualify for a Special Enrollment Period.

3/1/2015 – 6/30/2015 – ACA Employer Assessment: Large employers with 100 or more full-time employees should conduct a detailed analysis of whether any further changes should be made in plan eligibility rules to satisfy the 95 percent threshold in 2016 (up from 70 percent in 2015) under the ACA’s employer shared responsibility provisions.

Employers with 50 to 99 full-time employees who previously qualified for transition relief from the ACA employer shared responsibility provisions should finalize assessment of any eligibility changes and employee premium rates, for purposes of the ACA employer shared responsibility provisions.

Beginning in 2016, those employers are subject to the penalties under the ACA’s “play or pay” mandate.

7/1/2015 – PCORI Fee Due: July 31 is the annual deadline for payment of the Patient Centered Outcomes Research Institute fee (PCORI fee) of $2 per covered life for the preceding plan year.

9/30/2015 – EEO-1 Report: Organizations with 100+ employees are to submit the EEO-1 report by September 30. Repeat annually. Repeat annually.

10/14/2015 – Medicare Part D Notice: Employers are to provide notice to all Part D eligible individuals, or those about to become eligible, prior to October 15 of each year who is covered by an employer health plan with outpatient prescription drug coverage, regardless of whether the employer coverage is primary or secondary to Medicare. The notice must be provided to all Part D eligible individuals, whether covered as active employees, retirees, COBRA recipients, disabled indivdiuals, or as dependents. Plan participants are Part D eligible if they are 65 or more years old, three months before turning age 65, and/or if they are disabled.

Note: If you provided participants with the all-in-one Employee Notification service provided by HR Service, Inc., this notice is included.

Varies, based upon plan year – Form 5500: File Form 5500 annually, by the last day of the 7th month following the end of the plan year (e.g., July 31 for calendar year plans).

 

For additional information, employee notices, links, and renewal reminders, login to our service at

www.HRServiceInc.com.

To download the Compliance Calendar for 2015, click here.

 


ACA employer mandate in action: Avoiding the missteps of 2014

 

Originally posted December 12, 2014, by Deborah Hyde on Employee Benefit News.

Soon we will be ushering in the New Year, which marks the first for the roll-out of the employer shared responsibility provisions under the Affordable Care Act. Though numerous guidelines were put forth to inform employers of how to satisfy the requirements under this employer mandate, 2014 also provided an opportunity to understand ways in which employers will fail (or at the very least, struggle) to meet these same obligations.

Cutting corners

Faced with the requirement to provide medical coverage to an expanded population of employees, some employers sought strategies that required the least amount of commitment while still meeting the demands of the law. “Skinny” or “minimum value” plans were just such a strategy, as these plans provided the absolute minimum amount of coverage to employees. The IRS and the Department of Labor, however, swiftly came down on these plans and stated that these plans do not meet the minimum standards contemplated by the ACA and therefore fail to satisfy the employer mandate.

Similarly, employers considered reimbursement arrangements as a way to provide funding for employees’ health expenses while avoiding the obligation to put in place a group plan. On several occasions, however, the government made clear that stand-alone reimbursement arrangements fail to comply with the ACA, regardless of whether done on a pre- or post-tax basis. Simply put, the IRS and DOL made clear in 2014 that cutting corners won’t “make the cut” at all.

Delaying the inevitable

Despite the overwhelming amount of rules that employers are facing, there are more on the horizon. Enforcement of certain provisions under the ACA has been delayed, and while this allows employers more time to prepare, employers should not postpone the creation of a competent strategy. For example, the ACA extends nondiscrimination rules to fully-insured plans. The federal government has stated that these nondiscrimination rules will not be enforced until more information thorough guidelines is provided, but employers would be wise to keep these rules in mind when designing health plans and avoid the need for a total re-design in the future.

In addition, Section 6055 and 6056 reporting to the IRS is not required until 2016. This requirement is over a year away, but employers need to be diligent in their preparations to efficiently and effectively meet this obligation. Putting in place a reliable HR reporting system now will avoid an unnecessary scramble later.

Denying the current Reality

The most detrimental strategy for compliance is for employers to deny the need to comply altogether. By now, it is clear that the employer mandate will be in effect in a matter of weeks. Employers should not hold out for significant changes to, or even a complete repeal of, the current law. A now-Republican majority in Congress brings with it much grandstanding and political rhetoric concerning a repeal of the ACA, but such discussion should be taken with a grain of salt. Any overhaul to the existing law won’t be seen for some time – if at all. And though the U.S. Supreme Court will soon be hearing arguments regarding the role of federally-established marketplace exchanges, the Court’s decision is not only many months away, but is unlikely to result in the unraveling of the employer mandate.

2015 will be the first year of enforcement for the employer shared responsibility rule, but in many instances, 2014 served as a prime guide for employers by highlighting not only the steps to take, but also the steps to avoid, in creating a successful compliance strategy.