Good afternoon or good morning, depending on where you are. Thank you for joining our webinar today. ACA compliance for PEOs in twenty twenty six. What you need to know now. My name is Robin Carlini, and I’ll be your webinar moderator today. And a little disclaimer before we get started. Solaris does not provide legal advice. We are ACA knowledge experts, but for your specific questions, you may still need to seek your legal counsel. Some housekeeping, this webinar is being recorded. All registrants will receive the recording tomorrow, and in your zoom you’ll see a Q and A box or even the chat box. You can type in your questions and we’ll answer throughout the webinar and towards the end. And also upon exiting the webinar there’s a survey if you don’t mind filling it out, it helps us, you know with this webinar contents and topics that we do monthly. And now for introductions. Have Michelle Kirschner, senior sales director here at Solarix and in charge of PEOs and Erin Piserno, manager of the PEO team. Michelle, can you go ahead and introduce yourself, Absolutely. Welcome, everybody. I’m excited to be here with you. I have been working in the ACA field for over the past fifteen years, so that’s prior to even the ACA inception. There were a lot of things going on. I specialize in the PEO world. I know many of you on this call today, and I’m excited to present to you and help you with some valuable solutions. Erin, do you wanna go next? Sure. Thanks, Michelle. I like Michelle, I’ve been in ACA for many years. I’ve been at Solaris just under two years now, but I have worked in ACA since the inception in twenty fifteen. Prior to that, I worked in human resources for about twenty two years. And my goal on the PEO team is really just to make ACA tracking and reporting as accurate, painless, and seamless as possible for our PEOs and their clients. Love it. I’m gonna dive in here, and I like to speak in regards to Solarix as a whole. And I know many of you may have known us previously by our name of SyncStream, but now we are Solirix. I’ll share with you a little bit of our history so that you know that. Last year, we were, working with UnitedHealthcare and now we are working with one in four companies in the United States who trust us to do their ACA services. You can see the amount of filing that we are doing. We’re not some fly by night company. This is something that we specialize in. Erin and her team specialize in the PEO world, as we know that this world is unique. So we really take your expertise at hand when we dive in on all of this. Oh, our experience with our PEOs. You hear me talking about, you know, how we work and what we do. PEO, employer of record, ASO, we know that all of those are unique capabilities, and we specialize in that area. Erin and her team work with many ASOs, PEOs, and employers of record. So it’s our goal to really focus and make sure that you know that we are diving in deeply into this world. We’ll work and, you know, Erin, I think a lot of people ask us, you know, Michelle, what is your specialty? What do you specialize? And we we don’t really we work with everybody. I can work with a very large PEO all the way down to a small PEO. Erin loves it when I send her that middle sized group. Right? Erin, that’s one that you go, oh my god. I love this size group because there’s a lot smaller ones, Michelle. Let’s go small ones. You like the big ones. I like the small ones. It doesn’t matter the size. We’ll take care of We want you to know we focus everywhere. Yeah. Just to touch on that, in twenty twenty five, the PEO team was responsible for filing over six thousand seven hundred EINs, and that was seven hundred and fifty thousand forms. So again, to Michelle’s point, it really doesn’t matter the or complexity. Have the experience to help you file regardless of how big or small. Love those numbers, Erin. That helps. Looks like we got a poll question. Robin’s going to jump in here and support us on this poll question. I’ll go ahead and launch our first poll. What is your current status with ACA reporting? I’m sorry, the polls don’t match up. Let’s go to A, I am a Solaris customer. B) Currently evaluating ACA vendors C) Using spreadsheets and manual processes, which might be tricky for a PEO, outsourced to a third party vendor or other. We’ll wait for those answers to come in. Thank you for answering our polls. This helps us understand who we have on the call and how we can operate and help you as we dive in today. Okay, guys, it looks like nine percent currently evaluating ACA vendors. So thank you for being here today. Eighteen percent using spreadsheets and manual processes. Thirty six percent outsourced to a third party vendor, and thirty three percent are other. Perfect. Well, it sounds like we have our work cut out for us, and we’re gonna dive in on all of those topics today. And we promise we’ll get you some good information so that all of you can feel confident and comfortable in your reporting for this coming year. So Erin and I are going to kind of talk back and forth because I really like to have open conversation during our webinars. We know PEO challenges with ACA reporting, and the biggest one, Erin, that you see, I believe, and I’d love for you to speak on that, is all of the not even the multiple EINs and what that looks like. Do you want to dive into that a little bit? Yeah, so this slide really just kind of shows you the pain points that we hear typically when we’re talking with PEOs, ALE determination. So who is part of the ALE? So an ALE is an applicable large employer. Doesn’t always mean that you have fifty FTEs. It could mean that you are part of a control group that has fifty FTEs. So you may only have ten, but you still have to file. So a lot of times, one of the one or more of the ALEs may not be a part of the PEO, And so the PEO has to get that information from the client. Eligibility tracking is a big one. Who’s tracking the eligibility? Is the client managing those hours and determining who’s eligible, or is the PEO doing it? Third, the measurement method. We hear a lot on this, right? Erin, we hear a lot on the measurement method. Yeah. That’s one that we really dive in. And Erin, I’d love for you to speak about your measurement method and the look back because many people say, I can only do one. So I’d love for you to speak about that a little bit. Yeah, measurement methods are really kind of industry based, so it really depends on your population. So do you have mostly full time population? Maybe it makes sense to do monthly because most everybody’s eligible. If you have a mostly part time workforce or seasonal workforce, maybe it makes sense to do like a twelve month look back. With a twelve month look back, it’s less work administratively because people aren’t changing eligibility each month. So that’s a big one in terms of can It doesn’t have to be a one size fits all for the PEO. Each client can have a different measurement method, look back monthly, whatever it may be. So there’s variations there. That is similar to the benefits piece of it. Sometimes the PEO may not administer the benefits, and they just do the payroll. And so there’s a disconnect on who’s doing what. And if the PEO’s doing payroll, who’s tracking eligibility because who has access to the data to determine eligibility? Affordability is the next one. Is the client really the best one to determine affordability? Like, do they understand the risks if it’s not you know, if the right affordability method isn’t used correctly? Do they understand the penalties that come along with when a plan is not affordable? And then employer I wanna I just wanna speak too quick on that affordability. Nine times out of ten, that employer group has no idea. And I’m sure many of the PEOs on this call today are going, that’s absolutely correct. We have to lead them to this process. So knowing that you have a client service rep with Erin’s team that works one on one with you to help you have those conversations or to dive deeper into that, that’s what the team is always there to help and support. Yeah. Sorry, Erin. Go ahead. Employer group. That’s okay. I think we’ll get into each one of these in a little bit more detail. But the last one is employer approval. Like, is responsible for approving the 1095s and 1094s? At the end of the day, the client is really the one that’s accountable to the IRS. But do you want to have them involved in the process and that approval process so that they have some ownership of it? Yes. Thank you. Now, Erin, let’s talk about a year round PEO compliance model because this is where I really sell Erin and her team because it is important for you to all hear that when we work with our PEOs, it may be thirty minutes a month. It may be forty five minutes a month, depending on the size of the PEO, but it’s really, really important that we are meeting on a monthly basis. Erin, do you want to kind of take this compliance model and dive into it a little bit? Yeah, I mean, we get pushed back all the time about saying, you know, well, why are we talking? It’s August. Like, can’t we talk about this in December or January when it’s due? You can’t really look at ACA reporting from when is it due perspective because it makes it a lot more challenging when it is due. If you can spend one to two hours a month just kind of reviewing eligible employees, you know, plan affordability, just kind of checking in on it monthly, it makes your year end so much easier and cleaner and quicker. But it’s really just, again, thinking that if they see compliance as a year round activity, like I’m making sure these employees that are eligible are being offered coverage. Once they’re offered coverage, am I entering enrollments or waivers in the system so so that everything comes through cleanly and is buttoned up for year end. I love that because our biggest thing, when we start working with clients, one of our PEOs came to us last year and said, and I’m going to share this story, One of our PEOs said, hey, I’m having a baby, and I’m gonna be going out of the office in February. And it was the main person who did all ACA. So we had them prepped and ready to go so that they went out on maternity leave and everything was filed. We had read receipts and everything was completed and done but that was because we prepped it all year long and made sure that everything was taken care of. Our biggest goal is to have you not running around with two firecrackers in your hands because you’ve got year end. You’ve got w twos. You’ve got ACA. Let’s take one of those off of the plate, and that’s why year round reported is so important. Alright. Let’s do a little refresher. I’d like to dive in. We’re just gonna go over a few things of who has to report, what does that look like. I I’m just gonna dive through this quickly just in case there’s, some beginning phases in this on this call today. Anybody who’s over fifty employees, that’s full time equivalent. The reporting is to the IRS to make sure that you are appropriately securing medical coverage and affordable coverage. All of the deadlines are put out there, and we make sure. I like to share, and Erin, I think your team, we post our deadlines for our clients a week ahead of the official deadline. Is that a correct statement? Yeah. I mean, it really kind of depends on printing and mailing deadlines, but we always file a week or two before we really have to just in case there’s some unknown situation like a EIN that’s not matching up. So we’ll always do it a little bit earlier than the final deadline. And we know and and I like to speak to this because we know we have some PEOs that we have to pull over the line because of the fact that they’re dragging their feet. We get it. You guys are busy, but we’re gonna stay with you and work side by side with you until everything is filed to the IRS and you are complete and you have guidance through that process. And again, if you’re doing it year round, then it makes your year end much easier. There it is. You know, I like to talk and Erin, I would love for you to talk a little bit about our control groups. And it’s funny because when we start diving into parent child, brother sister, and Erin and I were on a conversation just the other day, and someone was asking us the difference between parent child and brother sister. Here’s what I wanna share with you. We have expertise at our fingertips at all times. Our chief legal counsel, we can reach to him at any time, and he gives us guidance and leads us through. We want you to know that that is brought to you also when you are a partner with us. If you ever get into a control group issue that you’re going, how am I legally reporting to the IRS? And you have question in your mind if you’re doing it, we can help you through that. But Erin, will you talk about some of the challenges that you see with the control groups? Yeah, I think the biggest one is that employers may not even know that they’re part of a control group. So they may not even know that that common ownership exists. And there’s various types of common ownership that, you know, sometimes it’s percentage based. So it’s always just good to consult with your own internal counsel and say, you know, is there common ownership? The reason that common ownership is important is because it’s listed on the ten ninety four, and that’s how the IRS sees employers, right? So it wants to know, yes, you have more than fifty FTEs as an employer group, so multiple EINs. That’s why it matters. So again, as I mentioned before, you may only have ten employees within that client, but they could have common ownership, and therefore they are required to track eligibility, they’re required to file, and they have to be listed as an aggregated employer on that ten ninety four. Love it. I think it always helps to have the real life scenarios of what you’re seeing and hearing. I’m sure that’s resonating with people on this call today. Oh, our affordability safe harbors for twenty twenty six. You know, I’m gonna have Erin dive in on this. When we work with you and I I think what you’re gonna hear me always say is your PEO adviser, helper, who’s working with you is gonna talk about all of these different levels. We’re going to find out what you’re doing and how you’re doing it. Year one, when you come on with us, we’re going to take a lot of and Aaron, I’m going let you speak to this. We’re going to take a lot of what you’re presently doing and put it into play. When you get with us year two, we’re going to start talking about, hey, do you know if you tried this, this might work better for you. Do you want to take a scenario on that, Erin, and talk about that? Yes. So it’s important to remember that each employee only has to pass one safe harbor. So it is easiest if you, a PEO, say, oh, everybody passes FPL. Boom, the plan is less than one hundred and twenty nine dollars That’s a no brainer. But obviously, you’re gonna have clients that wanna have a plan employee contribution where it’s greater than that. And in that case, you may wanna use rate of pay or w two, but it’s tough from a PEO’s perspective because each client, the affordability has to be done differently and then again at the employee level. So our system does allow for that. So once you get to year end, you can say, okay, this is what this employee meets. They meet this one. I wanna use that one. So it can be different. You don’t have to have the same affordability across the board because, again, you could have a different industry. Maybe you have, like, a a restaurant group that are paid on tips mostly. Good example. Wanna include you’re gonna wanna use w two. Again, keep in mind, though, you don’t get that w two until the end of the year. Affordability, while you can do it once a year, you really need to be looking at it almost monthly to make sure that each employee, maybe their hours dip or their tips aren’t what they expected, then you’d still need to make sure that they’re passing another affordability. I love that scenario. That’s real life scenarios, and I’m sure many of the people are saying, oh yeah, I get that. But again, depending on if it’s a restaurant group, or if it’s a resort group, or maybe it’s light industrial, There’s gonna be a different variance for all of them. And again, having an advisor with your PEO and leading you and guiding you is what we do to make sure that you’re feeling ACA compliant and not going, gosh, I’m throwing spaghetti at the wall, boy, I hope it sticks because I do not wanna get a love letter. And we’re gonna talk about those love letters real soon. We we just talked about this a little bit, about why it’s different for POs, and that’s because you have to do it on such a broader scale. So you have to make sure that each plan is affordable, or there’s at least one plan that’s affordable for each employer group. And then, you know, who is doing that affordability? Is the client calculating affordability? Are they testing it monthly to make sure that each employee is meeting one of the affordabilities? And then what happens when you do have, like, some sort of contribution change during annual enrollment? Has that one been tested before the plan gets rolled out? And can it be supported if you get an IRS love letter, as Michelle calls it? I call them love letters because in all honesty, penalty is such a pungent word. So let let’s give it a a different spin. Don’t want any love letters. Just for the record. We we we’ll dive into love letters here in a little bit and talk with you about that. But let’s go with some common questions from PEOs. I think we have a poll here, Rob. Oh, not yet. Look, I’m getting all excited. Common PEO questions and who is responsible for the ECA reporting? Erin, you deal with this a lot when you’re having conversations and, you know, depending on if you’re a CPO, what that looks like, are you a PEO? Will you give a little bit on this one, Erin? Yeah, I think it really comes down to in most cases who’s managing the benefits. So generally, obviously if the PEO is managing the benefits and they have access to that data, they’re going to do the ACA reporting. But maybe the client’s working with a broker or the client’s managing their own plan. Then the question becomes, well, whose responsibility is it? Again, the IRS will always see it as the employer’s responsibility, But maybe your business service agreement with the client says, you know, we will do this part. You’ll maybe they’ll do tracking. We’ll do reporting. But the employer is always accountable, responsible at the end of the day. So it’s just something that should be discussed when onboarding new clients, who is gonna do what. Love that. And we do have a lot of those conversations that come up when you’re onboarding, and and many people like to ask about our onboarding process. We’re right there beside you diving in. But let’s talk about some of the common law employer and what that looks like. I love, for ACA purposes and responsibility, follow the common law employer, not simply the entity issuing the paycheck or the W-two. Erin, will you touch on that and just kind of go through some of the key points that you deal with and how you work with the PEOs in regards to this? Yeah, so in most cases with PEOs, most PEOs use the employer’s EIN, that’s what they file under. There are a few rare circumstances where they’re using the PEO or the employer of records EIN. So they’re filing under that one EIN, almost like an aggregated employer they’re doing that. But it really depends on who’s managing the employee schedule, who’s the supervisor, who has input into that individual’s duties and responsibilities? Who manages how the work’s performed? So that is really how the IRS will see the differentiator in terms of whose EIN is on the ten ninety four itself. There is an exception, and that is a certified PEO where you can use the PEOs EIN on the ten ninety four as the employer. Yeah, and we talked a little bit about the certified PEOs, and I don’t know if we have any on the call today, but we’re always asking questions as we’re reviewing in the process to make sure that we know how you’re operating and what you’re doing, and how we protect you in the process also to make sure. All right, where should PEOs use caution? I like this one because as you hear us saying, we’re gonna guide you, we’re gonna offer advice so that you can run your PEO, but here are some questions that Erin and her team will go over with you to make sure that we’re keeping you in line. Erin, you want to dive in on them? Yeah, so this is where we always say, well, did you talk to the client about this? Was this discussed? Is this in the business agreement? It’s that type of thing where we wanna make sure who do we know who’s tracking eligibility? Does the client have the ability to track eligibility? And if somebody’s eligible, do they know what to do? Do they need to kick off offering coverage, or does the PEO do that? Who’s responsible for filing the forms at the end of the year? In many cases, if a broker or the client itself manages the plans, the PEO doesn’t have the necessary data to do that filing. So there might need to be a data transfer to get the full picture to be able to report. And then the other consideration we mentioned before is those control groups. Are there any other related ALE members that we need to consider when doing the filing so that when it gets to the IRS, all of the members of the control group are listed there? But again, it’s all about what was that initial discussion with the PEO when they were onboarded in terms of the roles and responsibility and taking accountability for who was doing what. Love it. Yeah. That’s really good life scenarios, which I’m sure people are going, oh, yeah. How about that? Alright. So now we’re gonna dive in on whose EIN goes on the ten ninety four and what does that look like. You’ve heard Erin talking about we have some of our PEOs that report at the PEO level under their PEO. But Erin, why don’t you dive in a little deeper on this one? And let’s talk about some of those common factors and practices that come into play. Yeah, we talked about this on a previous slide, basically it should, in most cases, be the employer’s EIN if they’re guiding the schedule, the work, the duties of the position. If the employer is the one doing that, then usually it’s their EIN. There’s a misconception that if you’re part of a control group, it’s the control group’s EIN that goes on. That’s not the case. Each ALE member must file individually. So there’s always going to be one filing per EIN. It doesn’t matter if it is part of a control group. That control group doesn’t take ownership of the filing. But again, in some cases, you can file under the PEO depending on the structure of how the work is done. Love that. That was real good. All right. What about ten ninety five distribution? As many of you know, the Paperwork Reduction Act has come into play. We have been lobbying for this since the inception. I think our Ashley Pope would always say, stop killing trees. Don’t be requiring paper. And, you know, what we know is in our staffing world and our PEO world, these are areas where it is redundant. There is a lot of people who change and aren’t at their address. So, we’ve been lobbying to have this paperwork reduction act come into play for years. We’ve been emailing forms to individuals since the inception. Now under the Paperwork Reduction Act, we have a portal that we can push back to. If you do not have one in your payroll solution system, we can push back to our Solarix portal, and they can get it out of our portal. We wanna help you reduce all of your costs and make sure that it’s efficient for you so you’re not paying for printing because by law, you no longer have to. We help you make sure that you’re posting and meeting the guidelines and putting everything in place so that you’re covered from the aspects of, yes, I posted it, all employees know, this will now be a change in our employee handbook. How we distribute w twos is how we’re gonna distribute ten ninety fives. We’ll dive in. And Erin, I believe you and your team discuss a little bit with them about that. Is that correct? Yeah. So to your point, at a PEO level, it’s got to be scalable. If you have ten thousand employees that you’re responsible for, maybe posting a notice of availability isn’t really realistic because then they could come to you like, oh, I need a ten ninety five. I need a ten ninety five. Maybe that’s not scalable, and you don’t want that to be handled that way. So we do have the portal. There’s different methods that clients use that we’ve seen. We have an integration with Prism HR, and so we’ll push the forms to Prism. So that’s one option. So even though you can just post that notice and make it available, sometimes just due to the scale, you don’t want to have to manage it that way. So in most cases, you’re providing them with some electronic copy. But the issue that we see is who’s posting the notice, right? Is it the client or is it the PEO? And in most cases, we recommend that they do both just to kind of cover their basis so the employee knows if I go to my own company’s website, it’s going to tell me. If I go to the PEO website, I know how to get it if I need to. That’s perfect. Thank you, Erin. All right. Here comes the risk in the PEO model. And now I think we have a poll question. There we go. Me go ahead and launch this one. Where does your PEO struggle with ACA compliance? Is it managing complex ACA reporting requirements, ensuring client data is accurate and complete, keeping up with the regulatory changes, identifying and resolving potential penalties, scaling ACA compliance across multiple clients, or is it all of the above? Where’s the easy button? I think we’re going to find, you know, in the PEO world, I think that a lot of them are gonna come in at half. But let’s let’s see where it lands. We really appreciate you guys doing these polls. This helps us. I know. And if I knew how to incorporate music here, I would. Right. Love it. We’re talking for us. Okay, so thirteen percent managing complex ACA requirements, twenty five percent ensuring client data is accurate, thirteen percent scaling ACA compliance across multiple clients, and the whopping fifty percent, all of the above. Where’s the easy button? We hope we’re your easy button, but Yes, and I’ll share with you. I think what really separates us is that we have a team like Erin. When we’re talking and you’re one on one with an individual, Erin and her team have these expertise and they specialize PEO. They specialize. They know the ins, the outs, the ups, the downs. They’ve been there, done that, seen that. But, you know, I I will always say, and and Erin and Robin heard me say this before, we we don’t have one PEO that’s alike. You all are unique little creatures, and whether you’re PEO, ASO, employer of record, we know you’re gonna operate a little bit unique. But the majority of those scenarios we’ve seen. So, we’d like to say been there, done that, and we can help you find the ease in your reporting. So, let’s dive in and take a look at what we have now and go through. Why mistakes matter. Well, you hear us talking about all kinds of risk and all of those options that are out there. Erin, I would love for you to talk about the operational impact that can really have and making sure that they feel that compliance confidence with you and your team. Yeah, and this goes back to the it’s a year round thing, right? If you’re making it a year round activity, you’re staying on top of it, you’re aware of the implications. Penalties usually happen for a multitude of reasons, right? Like maybe it’s an incorrect filing, incomplete filing. If we can avoid those, we’re also avoiding the impact of doing the refiling, right? Because that’s going to take a lot of time to go back and maybe get that data or analyze the data, figure out what was incorrect about it. So it’s not just the financial penalty, but it’s also the cost of the organization to do that refiling. You may have to pay somebody to do a prior year filing, redo a filing. So there’s, you know, there’s consequences to not getting it right the first time and not staying on top of it. I love it. You know, when we talk about fixing past year’s filings, we had a PEO group come to us just recently, and they got a penalty letter. And they were diving into it, and they’re going, Michelle, so if we reported this way for twenty four, do we fix our twenty five, or do we wait for that penalty letter to come? I always love that conversation because you could wait for the penalty letter to come for twenty five or you could get in front of it, correct your twenty four, correct your twenty five, send it into the IRS so that they see you’re being proactive. There’s many different angles and many different ways to take this. So when you work with us, we work with you in regards to all of that. All right, Erin, you want to talk about some of This is huge. I mean, This is a big one. Could go on for two hours on this. Go ahead. Yeah. You hear us say all the time, garbage in, garbage out. Right? You guys all know that term very, very well. But it’s basically there’s, you know, there’s disconnects between the system. So maybe, again, like the PEO is managing payroll and somebody else is managing benefits. If we can’t get those two systems to talk, we could have a disconnect in the data. So maybe this system is saying, well, this person’s eligible and this system over here doesn’t know that they’re eligible. And then maybe the workflow in terms of offering coverage isn’t getting kicked off. And then once if that offer does get made, does it come back to the other system? So this is a big deal for PEOs because they have multiple systems, maybe not potentially aligned. They have to figure out how to talk to each other through APIs or whatever. Obviously, ideally it works better in one system, but that’s not always possible. So it’s really important that those systems are aligned to make sure that the data is accurate. One of the things that I’ll always point out when we talk about this, no matter what your payroll platform, no matter where it’s coming in, we always tell you our system is the system of truth. Ours is regulated to the IRS updates standards so that you are being put in a regulatory system that’s monitored and watched regularly. So you don’t have to worry about what that misalignment is. We feed all the info into our solution, and then we get good data coming out. Good point. Yeah, this is a little bit more of a little detail You love mapping. You love mapping, right? Yeah, so this is why it matters. Like it matters what you call something. So maybe, you know, you’re calling somebody part time and the the client is calling it part time benefit eligible. Right? So it matters to us because the IRS only has three statuses, full time, part time, and seasonal. So you have to make sure that the client’s job codes, employee type statuses are being mapped correctly to the actual IRS statuses so that that you know, okay. This person is part time. Therefore, we’re tracking their hours for eligibility. This person’s full time, whatever you want to call it, it’s got to you know, it matters what it is and that everybody understands those terms so that you’re tracking them appropriately. I had a conversation with the PEO recently and, you know, actually, the client was saying, well, they’re part time. They’re not they’re not eligible. And I’m like, yeah, they’re part time, but they they they’re working up hours over the you know, they they are eligible. No. They’re part time. And so this kind of went back and forth because they didn’t understand the terminology in terms of they thought part time just meant they were never going to have to offer them coverage. But as an ALE, you may have to offer them coverage if they work the required hours. And I love that because those are the conversations. That’s the real life that we get into. And I always want to speak to this. When we do integrations with our payroll companies, you know, one of my integrations, we have over eight thousand hours into that integration, and we meet weekly with the payroll group to make sure that we’re updating, keeping everything in line. We keep everything at a very stringent process. We want to make sure that we’re protecting data, getting correct data because as Erin says, junk in means junk out, and that’s gonna mean a lot more when you’re trying to go to report and you’re getting all kinds of errors. And we’re talking to you about, oh, this is a red flag. This is a red flag. This is gonna cause a penalty. And that all comes up in our solution. So Erin and her team work regularly with you to make sure that this is being mapped out and mapped correctly. Your favorite, Erin. Yeah, talked about this a lot. Everybody’s pretty sick of us talking about it at this point, but common ownership. So how do you file? Who’s responsible? Multiple related entities may need to be counted together. I’ll use this as a chance to plug our system and our integration with PRISM. And actually, with any system, if you can provide us with FTEs for the prior year, we can help determine, are they an ALE? So a lot of times that’s what PEO struggle with is we just need help figuring out if they’re an ALE so we can tell them that they need to track hours and they need to offer coverage. So that’s a really big one. Like, do you understand what it means to be an ALE or part of a control group? And if need be, we can help you break down those numbers to get a definitive answer. Sometimes when they’re even close, like maybe they’ve got forty eight, we recommend that you start tracking them just so that you are aware once they hit that, they need to start offering coverage to eligible employees. Love that. And, you know, I want to just kind of pipe in here, Erin, because we get lots of conversations with our PEO groups that’ll say to me, Michelle, I got a few that are on the cusp, and Erin, we love this conversation. We also have PEO groups that go, I wanna throw everybody in here. I want you to track and report on everybody. We wanna have conversations with you to go, let’s make sure that we’re not over reporting. Let’s make sure that we’re looking at exactly what you need. Erin, do you wanna talk a little bit about to that? Because I know when we say in our scenario and depending on, you know, if it’s a restaurant group or if it’s somebody that has very high turnover. If you’re at forty five and you’re a PEO and you’re going, I’m watching this group. They’re at forty five. That’s a very feasible comment. If somebody’s at thirty seven, we’re not gonna wanna track them. Do you wanna talk to that a little bit, Erin? Because we do have a lot in that. Yeah. We we’ll see a lot of clients and or PEOs that kinda panic and they’re like, oh, we’re at forty eight. I’m gonna have to report. And it’s like, no, not necessarily. Like, you do have to hit that fifty and it’s an average over the prior So when we’re talking about twenty twenty six reporting, which we’re in, we’re actually looking at twenty twenty five. So we’re looking at those those FTEs from twenty twenty five, not twenty twenty, twenty twenty six. We just recommend that if you’re getting, like, over forty five, you start to look at it because then you know, okay, I need to get a benefit plan in place. Like, there’s a lot of steps leading up to it before you actually have to report. Yes, I love that one. And I always like to bring that up because that is a common PEO practice that is brought to Erin and her team. Okay. Alright. ACA reporting caution areas, common risk points for PEOs. You know, who posts the ten ninety five c notice of availability of forms are not mailed? We like to make sure that we’re keeping you to date with everything and what you need to know. What you’ll find about us is we’re thought leadership. We’re providing education. We do webinars monthly. We’re making sure that you know exactly how things need to be done. Who maintains copies of the current and prior year filings? Those are common practices. You will have a repository on our solution where you can find everything at your fingertips by year, along with the read receipt IDs and all of that information. Who responds if the ir IRS requests the documentation? Erin, do you get this one a lot? I would love to have your thoughts and feedback on who responds. I I know under our practice with Solirix, we have never had a client receive a penalty letter under our practice. Usually, our penalty letters come in with people who are brand new, but will you speak to that? Yeah. This is really an education piece. I think it’s important to tell your clients if you do see this type of love letter, any sort of documentation from the IRS, notify the PEO soon because the key here is responding timely. Like, if you can respond to these things timely and give them information, you could mitigate a lot of those penalties. So in in most cases, you know, maybe it’s best that the communication does come from the employer, but the PEO and potentially Solaris is guiding that communication. Like, we’ve, you know, we’ve got almost like boilerplate responses that may fit that we could give you that say, okay. You know, here’s how we suggest that you reply to this to mitigate this or to just request a refile if it was if if that’s what the case is. One of the things I just wanna talk too quick, we don’t need to talk about everyone on here, but midyear client. Erin and I love these conversations because, you know, we know that as PEOs, you’re acquiring business, you’re bringing on business, you’re doing different things. Mid year is a huge thing. So just know mid year clients will work closely with you in regards to this. Jump to the next slide please, Robin, and we’ll keep moving along. Know we’re getting One thing, can I just, I want to point out one thing about that? You do have a, a mid year is kind of a term that we use internally, but basically, it means that the client wasn’t acquired before January one. Right? So maybe they came on board with the PEO March. It’s kind of a misconception that the that that employer can have two filings with the IRS, they cannot. So you can only have one filing per year per EIN. So you can’t say, oh, they were with Equifax, Equifax is going to file and then you guys do this filing. You can’t do that. You’ve got to assemble the data together, and there can only be one filing. So either the prior PEO does it or the current PEO does it, but there really can only be one filing per EIN. Thanks for that clarification. That’s wonderful. We’re going to talk now on love letters, and I’m going to kind of speed through the love letters, but I’m going let Robin do this poll and then we’ll dive in. Yes, the penalty section shouldn’t take long and then we can answer your questions. How confident are you that your current ACA process would withstand an IRS audit? Are you very confident, somewhat confident, not very confident, or we’re not sure? I’m anxious to see where this comes in. We are now getting answers all across the board. And that’s okay. That’s good stuff. Yeah. Thirteen percent, very confident, fifty six percent, somewhat confident, ten percent, not very confident, and twenty percent, we’re not sure. Well, that’s good, you know? Yeah, not too bad. But then you’re here today, because hopefully we’re providing you some education. And as I said, we’re very big on thought leadership. We’re very big on informing and we’re very big with working with you so that you can feel confident and know exactly. We’re gonna dive in and Erin and her team, when they work with you, they’re gonna work with you one on one. They in our solution, it will pose a red flag. If there is an issue, Erin and her team may discuss it with you. You are up for the a penalty, or you are up for the b penalty. All of that we discuss regularly with you in those one on ones, so that you can feel confident and comfortable in knowing, my gosh, if I continue to report this way, you mean I could be up for? That’s absolutely correct, and Erin and her team will dive in on all of that with you. It’s best to have your practices in place and making sure I just had a phone call yesterday that somebody got a penalty letter from twenty twenty four, and they said, Michelle, here’s my biggest problem. I do not have this was three payroll companies ago, and I do not have payroll data for November or December. I’m like, what do you mean you don’t have payroll data for November, December? They’re like, we can’t we can’t find it. It wasn’t pulled. We’ve gone back to the payroll group. They can’t provide it. Here’s what I’m going to tell you. If you can’t provide data, you are up for penalties. If you can’t back up the documentation to the IRS, I can’t go to the IRS and say the dog ate your homework. I just can’t. That excuse no longer flies. You have to be able to back it up. So making sure that you have everything on this screen available is always important. And again, we house all of this in the repository, so you never have to worry about it. Next slide, Robin. Your internal ACA audit checklist. I love before a reporting season. Make sure, and again, this is what Erin’s talking about, meeting monthly, making sure this is everything that they’re going over with you on those calls, making sure that everything is in play so that we can tell that story to the IRS on lines fourteen through sixteen. Are we reporting correctly? Are we coding correctly so that it’s not gonna trigger flags to the IRS? We want to make sure that we keep everything timely and accurate. Some takeaways, things that I will always share with you, we are here to guide you. If you ever receive a penalty letter, we can help you with this process and make sure that everything is taken care of for you. We want you to know that it’s your job to run your PEO and then leave the ACA compliance to us so that you know you have an expert running that and you can keep your head down on your business and do what you should be doing. Okay. Last poll. Right? This is our exit poll. We won’t go over. Let me see. Did I how to did I launch it? Yeah. Oh, no, it’s not launched yet. Okay, let me go ahead and launch it. Is just for us to follow-up with so we won’t necessarily go over these answers. But what’s your next step after today’s session? Are you going to review your ACA processes internally? Are you going to look into tools and solutions to improve accuracy, discuss internally with your team? No immediate next steps, Or are you interested in more information about how Salerix can help? So, I’m going to leave that poll up as you answer and we’ll move on to the next slide. Perfect. Erin and I love to talk about how Celerix supports your PEO and ACA reporting. Erin and her team, I like to consider them your right hand because that’s what they do. Erin, do you want to jump in a little bit here and talk about your team and the reporting process? Yeah, I will say that I’ve worked with other AC systems, and this isn’t just my opinion, but a lot of our PEOs have said the same thing, that our system has so much more functionality than what they’re used to. So what the the main things what where our PEOs find value is that we can support both monthly and look back measurements. You don’t have to do one or the other for the entire PEO. You can have that individual choice. We can identify employees coded as full time who may not be working full time. So maybe somebody’s, you know, supposed to be working forty hours a week, but we’re looking at their hours over time and they are eight. You know? So does that justify, like, a change in status or just looking at that person’s position? It’ll flag employees who are eligible based on hours, and it can do that again by different statuses. It tracks eligibility across control groups as we’ve spoken about. This one, I really like it, manages the rehire rules. So there are rehire rules where somebody leaves the organization and they’re rehired within thirty thirteen weeks or twenty six if it’s a school, then you do have to put them back into that same measurement period. So if you’re currently tracking this stuff manually, that’s where it becomes difficult. Like, did they rehire? I need to make sure that they’re in that same measurement period. I don’t just start a new one. Our system does that automatically. It also tracks employees that are working in different EINs, but within the control group. So again, that restaurant example where somebody’s working at three restaurants, it’s gonna look at them as a whole to make sure that they’re getting you know, their hours are looked at as one, not three different employers, but one employer. And again, it supports different affordability methods by EIN, and you can select affordability by employee. So you don’t have to just do one size fits all. And then finally, we’ve got the capability to do different distribution methods, whether that’s our portal, your portal, electronic delivery, printing and mail. All the options are available, again, by EIN, not necessarily at the PEO level. So just real granular level options to fit the PEO’s needs. Yeah, I love that because that is the key piece is making sure that you have a solution that ties in to what works for your PEO. It’s not something that you go, okay, well, this is what I get, so I’m just going to use it. We have really thoughtfully considered this at a PEO level, so that you can feel confident and comfortable in knowing how that reporting goes in. Okay, and now we can take your questions, and we have some QR codes that are helpful here as well that you can go snack. Again, I’ll be sending everyone the recording. I’ll include our PEO page. You have Michelle’s information, but I want to go ahead and get some questions in while we have time. Sure. One just came through. How would Solaris handle it if a client of the PEO is approaching ALA status fifty or more, but not yet an ALA? You know, we did touch on that a little bit. Yeah, we did. And Erin spoke about that, but you know, if you’re getting close, we’re gonna help you monitor. We’re gonna dive in, and if you want some more one on one with that, we can absolutely speak with you. Again, remember that our reporting is a year in the rears, So we love to talk about we’re reporting a year in the rears. So we’re happy to dive in if anybody has any further conversations. Let me know when we can do that. All right, another question. If the client offers their own benefit plans, can we still complete their reporting? Erin, you want to take that one? What was the question again? If the client offers their own benefit plans, can we still complete their reporting? Yeah. We have quite a few PEOs where they do the reporting for maybe eighty or ninety percent, but then there’s, like, that ten percent that they’ve got their own plans. It makes it a lot easier if we do have access to that payroll and the census data. And then the only piece that we’re getting is, you know, the plans and the offers, which we can certainly get from the client. So we can, you know, we can facilitate that or you can facilitate getting that data, but we can definitely offer reporting for those groups where we don’t manage the benefits. And Erin, you see a lot in the PEO world with the Master Health Plans, and then there may be individual plans. So we see many different scenarios that come through. Would you agree with that, that there are scenarios that are unique and different? Yeah, one of the struggles we see with some of the PEOs is that it’s like, well, the bulk of our clients are on these master plans with the same renewal, but then you’re always gonna have those unique situations where maybe the renewal dates vary. That’s fine. Our system can handle variations in renewal date because everything’s at the EIN level with the brand or the PEO functionality. But yeah, it’s set up to handle the complexities and plans that are like that. Love it, love it. Okay, does a PEO need to choose the same measurement periods for the entire PEO or can it vary by client within a PEO? Yes, it can vary by client. So with within an EIN, you should have the same measurement method. So you’re treating that population the same. So either monthly or either look back, not both, but you can definitely it’s, again, not a one size fits all for the PEO where you’ve got to choose one or the other. You’ve got that flexibility to choose either or at the client level. I think one of the things that I want to just bring up, Robin, is making sure that you understand. We created our software, we created it to make sure that it specializes for PEO, and we know the complexities that come at hand with PEO and how that operates and works. So we like to think that we have each scenario in play, and and we can really work with your group to find the finites that are brought to the table with each PEO because you are unique. Very good point. And this one, they’re researching vendors. So this goes back to our first poll. They must have answered that one. When should they onboard? When is it too Here’s what I’ll tell you. I always have the sense of urgency because with Erin and team, Erin, while she loves me, she hates me when I come to her in November and go, hey. I got this group, and don’t worry. We’re gonna cram eleven months worth of data into one month. Do you think Erin likes me? No. Erin does not like me. Erin would like to jump off the roof of her house and go, seriously, Michelle. So here’s what I’ll tell you. I know that every group is a little bit unique. We work with you to make sure that everything is done to the IRS standards, and that’s what’s important to us because that’s what we pride ourselves in. Is it better to have you under our belt six months in advance so that we know how you work and know what you do? Yes. Is it best to get moving right now? Yes. If you are looking, it is now is the time. I will share with you that Erin and team can onboard right now, and we’re looking at a two week onboard. But that means she has to pull in data, review data, follow that data, look at that data, and remember, we’re reporting a year in the reels, and when we bring you in, we’re requesting two years worth of data because we wanna review that and make sure that it’s accurate and complete. So the sense of urgency is at hand so that Erin doesn’t hate me. That’s what we want to hear. Right, Erin? Yeah. Well, I was just gonna say, I mean, obviously we can onboard whenever. Prefer doing it sooner because that gives us the time to really analyze the information that we’ve been given rather than, oh my gosh. We have to kinda cram it in because we’ve gotta meet this deadline. And Michelle hasn’t plugged my team enough, so I’ll do it as well. But they are all ACA experts, and some of them have even worked for PEO. So they understand the challenges of being with the PEO and the scalability. But a lot of times they will look at a client’s data or their process and say, that’s not right, or I don’t think that’s right. Can we talk about it? And then, you know, we can kind of look at the way, do we have flexibility in how we can report this because it is challenging. So that’s really the important part of coming on board where we really have time to have those conversations and discuss processes because we, you know, we want to help you make it easier, smoother, better. So it is not so much work going forward. I love that. Love Yeah, Erin and her team deserve all the plugs in the world because I’ll share with you, they are experts that deliver, which is the difference. And they deliver with success and guide you as PEOs. Thank you. Well, is a perfect way to end this. Yes. I want to thank Erin and Michelle for a wonderful presentation and thank everyone for spending time with us. It’s August, so you’re sitting pretty, I believe. I mean, you still have time. So thank you so much for that. And you’ll get the recording and you have Michelle’s information and she can’t wait to hear from you. I look forward to talking to all of you. Erin, Robin, thank you so much. And here’s to twenty six reporting year success. Let’s go. Let’s go. Bye. Thanks all.
