Patient Protection and the Affordable Care Act Overview
The Medical Trust's Compliance History
Healthcare reform began in earnest in March 2009. In one year, it moved from a proposal to passage by the Senate and the House of Representatives, and on March 23, 2010 the Affordable care Act (ACA) was signed into law by President Obama.
In 2009 with the passage of the Denominational Health Plan (DHP), the Medical Trust became the provider of medical benefits for The Episcopal Church. The Medical Trust knew its plans would be impacted by the ACA, and kept abreast of the legislation, which continues to evolve to this day.
How The Medical Trust Complies
The Medical Trust's plans are in compliance with all current provision of the ACA. In fact, the Medical Trust had instituted many of these provisions prior to healthcare reform, as they were in the best interests of those we serve.
The ACA imposes new reporting requirements on employers and plan sponsors that will assist the Internal Revenue Service in determining compliance with two ACA mandates:
- The Employer Mandate - the requirement for large employers to offer health coverage to their full-time employees (Forms 1094-C and 1095-C)
- The Individual Mandate - the requirement for individuals to obtain health coverage (Forms 1094-B and 1095-B)
Failure to comply with these mandates may result in the individual and/or employer being subject to additional taxes.
Health Reimbursement Arrangements
The reporting requirements for small and large employers that sponsor a Health Reimbursement Arrangement (HRA) and participate in a health plan sponsored by the Medical Trust have been updated by the IRS.
- Small employers may also need to prepare separate Forms 1094-B and 1095-B.
- Large employers may also need to complete Part III of Form 1095-C.
What does this mean to my organization or diocese?
If your organization or another organization in your diocese is a “large employer” (as defined below), you or that other organization will be responsible for filing the Employer Mandate tax forms (Forms 1094-C and 1095-C). See More Information about Reporting for details.
If your organization or another organization in your diocese is NOT a large employer (as defined below), you or that other organization are considered a small employer. If you do not sponsor an HRA, you will not be required to take any action as a result of these new reporting requirements.
- Small employers that sponsor an HRA and participate in the health plans sponsored by the Medical Trust may be required to prepare and file separate Form 1094-B and 1095-B for their employees.
The IRS tax forms (Forms 1094-B / 1095-B) required for the Individual Mandate must be provided to employees covered by a healthcare plan for both large and small employers. The Individual Mandate tax forms will be filed by either the Medical Trust or, in the case of fully insured medical plans, the insurance carrier. Therefore, you and organizations within your group that participate in the Medical Trust plans are not responsible for filing the Individual Mandate tax forms.
- Note, however, that small employers that sponsor an HRA may be required to prepare and file separate Forms 1094-B and 1095-B for their employees. If you sponsor an HRA, please review Notice 2015-68 and consult your tax advisor.
Please see More Information About Reporting for details regarding the IRS forms, timelines, and resources.
Please note that this update is provided to you for informational purposes only and should not be viewed as investment, tax, legal or other advice. Please consult your own professional advisors for further guidance.
Health benefits are offered through plans maintained by Church Pension Group Services Corporation (doing business as The Episcopal Church Medical Trust), 19 East 34th Street, New York, NY 10016.