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Looking Forward After King v. Burwell

Looking Forward After King v. Burwell
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by Jason Cogdill on 26 June, 2015 with Add new comment

The long-awaited Supreme Court decision is final. Much like June 2012, the ACA has survived another significant challenge, and it is once again full steam ahead for compliance with the law. I was not surprised by the result, but it was striking to see the 6-3 margin and the strength of position expressed by the Chief Justice in his majority opinion. After King, it is very unlikely that any other legal challenges will impact any major provisions of the law. Going forward, any significant modifications will have to come from the legislative process.

Key ACA Compliance Topics

Looking ahead, what is most important from an ACA compliance standpoint? These 3 items remain the most critical for employers:

  • Play-or-Pay compliance for employers subject to the mandate in 2015 (those with 100 or more FT + FTE calculated during 2014);
  • New ACA reporting requirements applicable in 2015 for employers with 50 or more FT + FTE (calculated during 2014); and
  • Play-or-Pay planning for 2016 for employers with 50 or more FT + FTE (calculated during 2015).

Reporting Update

Heading into the 3rd quarter, I encourage you and your team to do a full assessment of preparation for the new reporting requirements. As a quick update, last week the IRS released the new 2015 forms in draft form. Copies of Form 1094-C and 1095-C are attached below for your convenience. As expected, the new forms include very minor tweaks from the 2014 forms that we have been studying.

Earlier this month, the IRS released updated FAQs on the reporting requirements. If you have not seen those, you can access them here and here.

The IRS has not released updated instructions for 1094-C/1095-C as of yet, and I anticipate additional guidance later this summer. Until then, employers need to continue to focus on data tracking and also assessment of whether they will conduct the reporting internally or outsource to a third party.

Final note

I hope that you will have a break from the frenzy this summer and enjoy some quality time with family and friends. If you need assistance with any other ACA or compliance topic, let us know.

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Jason Cogdill

Jason Cogdill

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