September 2016, Vol. 2

Small districts and ACA transition relief

A school district that averaged 50–99 full-time employees, including full-time equivalents, during 2014 may have claimed an exemption from the requirement to offer coverage and the affordability requirement under the Affordable Care Act (ACA) until the first day of the 2016 plan year. To take advantage of this exemption, the school district was required to satisfy certain conditions, including maintenance of workforce and maintenance of health coverage, and to certify its eligibility with the IRS in early 2016. [79 Fed. Reg. 8574 (Feb. 12, 2014)] Whether or not the district claimed this extension, the district should have complied with applicable ACA reporting requirements.

This transition relief applied to all calendar months of 2015, plus any calendar months of 2016 that fell within the district’s 2015 plan year. [79 Fed. Reg. 8574 (Feb. 12, 2014)] The shared responsibility requirements for this group of employers then went into effect the first day of the 2016 plan year, which for TRS Active Care districts was September 1, 2016.

Any districts that took advantage of this transition relief must now prepare to document an offer of affordable coverage to all eligible employees for each month of the 2016 plan year. For more information on this and other requirements under the ACA, see TASB Legal Services resources available here