TRS clarifies ACA enrollment reporting requirements, will assist ActiveCare districts

The Teacher Retirement System of Texas (TRS) recently notified the Texas school districts that participate in TRS-ActiveCare that the PPO plans it offers (TRS-ActiveCare 1-HD, TRS-ActiveCare Select, and TRS-ActiveCare 2) are considered “self-funded multiple employer plans.”
TRS initially said that districts with employees enrolled in a TRS-ActiveCare PPO would be responsible for doing all the Affordable Care Act (ACA) enrollment reporting required by the Internal Revenue Service (IRS).
Since then, TRS has come up with an alternate solution to help participating school districts handle enrollment reporting and comply with IRS requirements. As the plan sponsor, districts will be able to delegate to TRS reporting requirements for employees or COBRA participants who are enrolled in any of the PPOs listed above. TRS will provide more detailed guidance on how the process will work within 30 days. 
At present, we expect that districts that want to delegate enrollment reporting to TRS will have to do the following:

  • Notify TRS by a set date—probably before the start of school—that they want the agency’s assistance.
  • Sign a written agreement, as required by IRS rules.
  • Agree to collect spouse and dependent Social Security Numbers or tax identification numbers for all those enrolled in health coverage, including COBRA participants. IRS rules require two attempts to obtain that information.
  • Agree to provide TRS with updated employee addresses by a set date each year.
  • Pay the cost for printing and mailing statements to employees (estimated at $1 to $3 per employee per calendar year—basically the costs TRS incurs in the process).
  • Districts will still be required to file reports on full-time employees by completing Parts I and II of Form 1095-C.
Districts that have their own self-funded insurance coverage should check with their third-party administrator to determine responsibility for reporting requirements.
School administrators who participated in our recent ACA Reporting Requirements Webinar should note that none of the information provided has changed; districts that want to do the reporting on their own can do so. For those that didn’t take part, an audio recording of the Webinar complete with detailed handouts is available for purchase ($75) on HR Services’ Website.

Going it alone

Self-insured large employer districts that choose to do their own enrollment reporting must complete and file the IRS Form 1095-C, “Employer Provided Health Insurance Offer and Coverage,” for each enrolled employee, full-time or not, and all COBRA participants. Enrollment information will be reported in Part III.  Self-insured districts that aren’t large employers must complete and file Form 1095-B, reporting essentially the same information for all employees that enrolled in coverage in 2015.
Self-funded districts that aren’t in TRS-ActiveCare should be able to get reporting assistance from their third-party administrator or a consultant.

Reporting deadlines

The deadline to provide statements to employees (Form 1095-C and, if applicable, Form 1095-B) is Jan. 31, which happens to be a Sunday in 2016. As a result, districts will have until Monday, Feb. 1 to provide employees with statements.
Districts that submit their reports to the IRS on paper have until Feb. 29, 2016. Those that want to submit their information electronically have an extra month, with submissions due on March 31, 2016. Districts with 250 or more employees are required to file their reports electronically, and those with less than 250 employees are encouraged to file electronically.