• On Dec. 16, 2015, the IRS clarified how employers should count defined contribution amounts for purposes of (1) the employer mandate’s “affordability” test and (2) reporting the employee’s required contribution for health coverage on Line 15 of the Form 1095-C.
• Unfortunately, interpreting this guidance is not easy, and confusion still remains on how exactly employers should count contribution amounts that are offered to employees (1) to purchase major medical, dental, or vision coverage, but also contribution amounts (2) to purchase supplemental products (such as disability, critical illness, and specified disease coverage, among others) and to even make an HSA contribution.
• The IRS did offer some transition relief for compliance with this new requirement, but you will need to understand whether you can rely on the transition relief or not.
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About our Presenter
Christopher E. Condeluci is principal and sole shareholder of CC Law & Policy PLLC in Washington, DC. Chris’s practice focuses on the Patient Protection and Affordable Care Act (“ACA”) and its impact on all stakeholders. Prior to forming CC Law & Policy, Chris served as Tax and Benefits Counsel to the U.S. Senate Finance Committee. During his time in Congress, Chris participated in the development of portions of the ACA, including the Exchanges, the insurance market reforms, and all of the new taxes enacted under the law. He is one of the few senior Congressional staffers who actively participated in the health reform debate to join the private sector since the ACA’s enactment, and based on his experience as an employee benefits attorney, he possesses a unique level of expertise on matters relating to tax law, ERISA, and the ACA.