2017 ACA Reporting Deadline Extended by 30 Days

Today, the IRS issued IRS Notice 2018-06, extending the deadline for providing the 2017 Forms 1095-B and 1095-C to individuals by 30 days.  This Notice mirrors the same 30-day extension provided last year for the 2016 ACA reporting. As a reminder, applicable large employers (ALEs) provide the Form 1095-C to individuals. If the plan is […]

Measuring Hours and Offers of Coverage

Question:  When does an ALE need to offer coverage to a part-time employee who start working full-time hours to avoid potential pay or play penalties?  The ALE utilizes the look-back measurement method for determining full-time employee status.  Compliance Team Response:    Reminder: Very Different Approach Depending on Measurement Method There are two different approaches for […]

Trends in Work Related Injuries and Illnesses

The Department of Industrial Relations has reported California’s 2016 occupational injury and illness data. Data collected by the U.S. Bureau of Labor Statistics’ Survey of Occupational Injuries and Illnesses showed California’s overall incidence rate was at the lowest it has been in over a decade, with a reported 3.7 cases per 100 full time workers. […]

ACA Form W-2 Cost of Coverage Reporting

Question: Which employers are subject to the ACA Form W-2 cost of coverage reporting? What coverage must be reported? Compliance Team Response:   Employers Subject to Form W-2 Cost of Coverage Reporting The Form W-2 cost of coverage reporting in Box 12 using code DD was added in the ACA, effective for 2012, and remains […]

Failing the Dependent Care 55% Average Benefit Test

Question:  What happens when highly compensated employees have already contributed more than the reduced contributions limit from the dependent care FSA nondiscrimination testing?   Compliance Team Response:    Unfortunately, it is very common for employers to fail the 55% Average Benefits Test component of the Dependent Care FSA NDT.  It’s a test that’s almost designed […]

New SF HCSO Waiver Form Updated November 1

The San Francisco Office of Labor Standards Enforcement (OLSE) has posted a new Employee Voluntary Waiver Form for use on or after November 1, 2017.  The form permits employees to voluntarily waive their right to employer health care expenditures under the San Francisco Health Care Security Ordinance (HSCO). HCSO Basics Under the HCSO, employers with […]

Bicycle Commuting Expense Reimbursement

Question:  What are the rules surrounding tax-free bicycle commuting expense reimbursement?   Compliance Team Response:    Overview The ability for employers to reimburse employees tax-free for bicycle expenses related to commuting was added to the Internal Revenue Code in 2009. The key limitations are: Employee contributions are not permitted (must be exclusively an employer giveaway […]