G-PRS 10/29/2015 SPECIAL SITUATIONS

Self – Insured Plans Major and HRAs [HRAs later] G-PRS 10/29/2015 Self – Insured Plans Major and HRAs [HRAs later] Filing as MEC provider (in addition to ALE) More to complete (e.g., Part III on 1095 – C) Different 1095 for each full-time employee AND others enrolled Non-full time employees Employee and those covered through employee (Part III 1095 – C) 1095 for each non-employee enrolled Alternatively, B series

Retirees Self-insured plans Year in which retire 14 15 16 G-PRS 10/29/2015 Retirees Self-insured plans Year in which retire 14 15 16 Months up to month retire 1E # 2C Month of retirement 1E # 2C Rest of that year 1H* -- 2A Years after year in which retire 14 15 16 1G* -- 2A * Remember: Fill out Part III C indicating months actually covered

COBRA QE: Employee termination of employment Self-insured plans G-PRS 10/29/2015 COBRA QE: Employee termination of employment Self-insured plans Year in which terminate 14 15 16 Months up to month term 1E # 2C Month of term 1E # 2C Rest of that year 1H* -- 2A Years after year in which retire 14 15 16 1G* -- 2A * Remember: Fill out Part III C indicating months actually covered

COBRA QE: Employee reduction hours (still employee) Self-insured plans G-PRS 10/29/2015 COBRA QE: Employee reduction hours (still employee) Self-insured plans Year in which reduce 14 15 16 Months up to month red 1E # 2C Month of red 1E # 2C Rest of that year 1H* -- 2C Years after year in which reduce 14 15 16 1H* -- 2C * Remember: Fill out Part III C indicating months actually covered

COBRA QE: Separate QB election (e.g., divorce) Self-insured plans G-PRS 10/29/2015 COBRA QE: Separate QB election (e.g., divorce) Self-insured plans Year in which QE occurs 14 15 16 Months up to month QE Part of employee’s 1095 Month of QE Part of employee’s 1095 Rest of that year 1G* -- -- Years after year of QE 14 15 16 1G* -- -- * Remember: Fill out Part III C indicating months actually covered

Non-Calendar Plan Year G-PRS 10/29/2015 Non-Calendar Plan Year Still have to file for 2015 calendar year Not penalty assessable until start of 2015 plan year Not automatic; must qualify   1094 C Line 22, Box C -- 4980H 1095 C (months prior to 2015 plan year start) Line 14 1H Line 15 Blank Line 16 Code 2I

Multiemployer Interim relief for 2015 only Special Code Combo G-PRS 10/29/2015 Multiemployer Interim relief for 2015 only Special Code Combo Line 14 1H (no offer) Line 15 blank Line 16 2E (multiemployer interim relief) Just for: Months contributions made for that person under CBA or PA Plan coverage that is MEC, MV and affordable

HRAs Do you offer an HRA? What kind(s) of HRA? G-PRS 10/29/2015 HRAs Do you offer an HRA? What kind(s) of HRA? Integrated Retiree only Do you need to do a filing for that HRA? Integrated – maybe Retiree -- yes Special issues Dependent/spouse eligibility when not under integrated Once integrated is gone What form?