Tuesday, 27 September 2016
Employer Alert - IRS Email Scam
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The newest scam involving a fraudulent email notice from the Internal Revenue (IRS) may have your employees coming to you asking about their insurance coverage for 2014.

The Internal Revenue Service late last week issued an alert to tax payers and tax professionals for an IRS scam related to the ACA. 

Please review the following information released from the IRS and distribute to any employee who may notify you that they have received the fraudulent email. It gives details on the fraudulent notice, how to report to the IRS receipt of the fraudulent email and instructions to delete the email.

Also as noted below, it is important to know that the IRS does not send out any notices by email to tax payers. Their practice is always to begin communication with tax payers through the mail. 

The IRS has received numerous reports around the country of scammers sending a fraudulent version of CP2000 notices for tax year 2015. Generally, the scam involves an email that includes the fake CP2000 as an attachment. The issue has been reported to the Treasury Inspector General for Tax Administration for investigation.

The CP2000 is a notice commonly mailed to taxpayers through the United States Postal Service. It is never sent as part of an email to taxpayers. The indicators are:

  • These notices are being sent electronically, even though the IRS does not initiate contact with taxpayers by email or through social media platforms;
  • The CP 2000 notices appear to be issued from an Austin, Texas, address;
  • The underreported issue is related to the Affordable Care Act (ACA) requesting information regarding 2014 coverage;
  • The payment voucher lists the letter number as 105C.

The fraudulent CP2000 notice included a payment request that taxpayers mail a check made out to "I.R.S." to the "Austin Processing Center" at a Post Office Box address. This is in addition to a "payment" link within the email itself.

IRS impersonation scams take many forms: threatening telephone calls, phishing emails and demanding letters. Learn more at Reporting Phishing and Online Scams.

Taxpayers or tax professionals who receive this scam email should forward it to phishing@irs.gov  and then delete it from their email account.

Taxpayers and tax professionals generally can do a keyword search on IRS.gov for any notice they receive. Taxpayers who receive a notice or letter can view explanations and images of common correspondence on IRS.gov at Understanding Your IRS Notice or Letter.

To determine if a CP2000 notice you received in the mail is real, see the Understanding Your CP2000 Notice, which includes an image of a real notice.

A CP2000 is generated by the IRS Automated Underreporter Program when income reported from third-party sources such as an employer does not match the income reported on the tax return. It provides extensive instructions to taxpayers about what to do if they agree or disagree that additional tax is owed.

It also requests that a check be made out to "United States Treasury" if the taxpayer agrees additional tax is owed. Or, if taxpayers are unable to pay, it provides instructions for payment options such as installment payments.

The IRS and its Security Summit partners the state tax agencies and the private-sector tax industry are conducting a campaign to raise awareness among taxpayer and tax professionals about increasing their security and becoming familiar with various tax-related scams. Learn more at Taxes. Security. Together. or Protect Your Clients; Protect Yourself.

Benefit Advisors Network and its smart partners are not attorneys and are not responsible for any legal advice. To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.

© Copyright 2016 Benefit Advisors Network. Smart Partners. All rights reserved. 

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Posted on 09/27/2016 7:48 PM by David Johnson
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Wednesday, 21 September 2016
Enrollment Counts for Transitional Reinsurance Fee Due Nov. 15, 2016
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Employers with self-insured major medical plans are reminded to report their membership count to the U.S. Department of Health and Human Services ("HHS") via the pay.gov website by November 15, 2016, as part of the Affordable Care Act's ("ACA") transitional reinsurance fee (the "Fee").   

The Fee is assessed on both insured and self-insured group health plans, and applies on a calendar year basis from 2014-2016.  Carriers offering group health insurance and sponsors of self-insured medical plans are required to pay the Fee to support payments to carriers in the individual market that cover high-cost claimants.  Carriers pay the fee on behalf of fully insured plans; employers are responsible for paying the fee for a self-insured plan.  Below is a brief summary of key dates and information for employers:

  • October 3, 2016: 2016 ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form should be available on www.Pay.gov.
    • When the Form becomes available, a notice will be sent to REGTAP registrants.
    • Employers may visit https://www.REGTAP.info to register.
  • November 15, 2016:  Deadline for employers with self-insured plans to report their annual enrollment of covered lives to HHS via the pay.gov website.
  • January 17, 2017:  Payment deadline if making a single payment ($27 per covered life).
    • $21.60 per covered life if making a two-part payment.
  • November 15, 2017:  Payment deadline for second payment for employers making a two-part payment ($5.40 per covered life). 

KEY INFORMATION FOR EMPLOYERS

  • The Fee applies to major medical coverage.
    • It does not apply to stand-alone dental and vision plans, prescription drug-only plans, HRAs, HSAs, FSAs, employee assistance programs (EAPs) and wellness plans that do not provide major medical coverage, post-65 retiree medical coverage, and plans that do not provide coverage that is "minimum value".
    • For 2015 and 2016, plans that are both self-insured and self-administered are exempt from the fee (i.e., the plan cannot use a third party administrator (TPA) in connection with claims processing or adjudication, including managing appeals, or for plan enrollment).
  • Employers are responsible for paying the fee for their self-insured medical plans.
    • TPAs may, but are not required to, complete the reinsurance contribution process, including payment, on behalf of a self-insured plan.
  • When paying the Fee, employers may need to contact their bank to add Agency Location Code (ALC+2 value) 7505008016 to its list of approved companies for ACH automatic debits.
    • The fee is $27 per covered life in 2016, down from $44 per covered life in 2015.
  • When a plan changes from fully insured to self-insured (or vice-versa) during the calendar year, the carrier is responsible for paying the Fee for the portion of the calendar year during which the plan is fully insured, and the employer is responsible for paying the Fee for the portion of the year during which the plan is self-insured.

MBWL Take-Away: Employers sponsoring self-insured plans should work closely with their benefits broker to select the most advantageous counting methodology. The counting methods can be complex and results may vary significantly based on the chosen method. Once the enrollment form has been submitted and the Fee paid, an employer cannot later amend that filing if it is discovered that another counting method would have been more advantageous.  2016 is the last year for which the Fee will be assessed.


About the Authors. This alert was prepared for Virtus Benefits by Stacy Barrow and Mitch Geiger. Mr. Barrow and Mr. Geiger are nationally recognized experts on the Affordable Care Act. Their firm, Marathas Barrow & Weatherhead LLP, is a premier employee benefits, executive compensation and employment law firm. They can be reach at sbarrow@marbarlaw.com or mgeiger@marbarlaw.com.

Benefit Advisors Network and its smart partners are not attorneys and are not responsible for any legal advice. To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.

© Copyright 2016 Benefit Advisors Network. Smart Partners. All rights reserved.

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Posted on 09/21/2016 7:32 PM by David Johnson
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