Background
The Affordable Care Act (ACA) created new reporting requirements under Sections 6055 and 6056 of the Internal Revenue Code (Code). The new rules require an applicable large employer (ALE) to report, on IRS Forms 1094-C and 1095-C, information about offers of health insurance coverage to full-time employees (FTEs) and the provision of minimum essential coverage (MEC). The Form 1094-C is also referred to as the “authoritative transmittal.” For 2016, an ALE is generally an employer with 50 or more FTE equivalents. Under Code Section 6056, an ALE must annually file with the IRS a report listing the offers of coverage made to its FTEs during the reporting year. In addition, ALEs must furnish a related statement of coverage information to FTEs. Under Code Section 6055, employers (including ALEs) who provide MEC under self-insured plans must also report MEC information for each individual covered under the employer’s self-insured plan.”
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Agenda
Faculty
Amy M. Gordon
Winston & Strawn LLP
- Partner in the Chicago office of Winston & Strawn LLP
- Regularly advises clients on their self-funded and insured health plans, wellness programs and on-site clinics; also works with service providers to structure these products for their plan customers
- Handles fiduciary issues, including prohibited transactions and other ERISA Title I matters and represents clients before the U.S. Department of Labor and Employee Benefits Security Administration
- Assists on-shore and off-shore investment funds in structuring their products to comply with the plan asset rules, or to avoid plan asset fund status; she is knowledgeable and provides guidance to master and feeder funds, VCOCs, and REOCs
- Assists clients and service providers in designing and maintaining compliant flexible benefit, life, medical, dental, pharmacy, employee assistance programs (EAP), educational assistance, disability, supplemental health, severance, health savings accounts (HSAs), health reimbursement accounts (HRAs), and other types of voluntary or ERISA covered welfare plans
- Consults with clients regarding the design of their plans, direct provider contracting options, and assists with compliance of wellness programs and initiatives; she has extensive experience with assisting clients who transition their employees and/or retirees to the public and private Marketplace Exchanges
- J.D. degree, Hofstra University; B.S. degree, Penn State University
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