The IRS released updated instructions for the 2019 filing of Form 1094-C and Form 1095-C. The two forms remain similar to last year’s versions, however, the instructions highlight the recent changes as announced in Notice 2019-63. Extension of due date to furnish Form 1095-C. 2019 Form 1095-C is due to employees by March 2, 2020 (instead of January […]
Keep exercise on your to-do list We’ve all been taught from a young age to f t in a little regular exercise. You know it’s I good for both your body and your mind. But when your day gets busy, it’s too easy to skip. When you get out of the daily habit, it’s hard […]
When an employer established an employee benefit plan (ERISA health and welfare plan), any contributions that employee’s make are regulated by ERISA as ERISA plan assets.
There are volumes of regulations regarding the classification and handling of plan assets. Basically, for small employer health plan contributions, the employer needs to ensure that the amount being deducted from the employee’s payroll is accurate – not more than the required contribution – and that it is remitted to the insurance carrier on the next billing cycle.
Where employers typically run into issues is where and an employee has been making contributions but the employer has not updated eligibility records with their insurance carrier – to add a dependent for example. The employer is collecting funds from an employee and not remitting to the carrier.
Another common occurrence is when an employee terminates in the middle of a month and they have made one or more premium contributions for the current month and the employer terminated their health coverage at the beginning of the month and does not properly reconcile and return the employees over-payment.
A complete reconciliation of employee contributions is recommended after open enrollment and then individual reconciliations when employees make changes to their eligibility or employment status.
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