When are contribution reporting forms due?
Contribution reports are due in this office by the fifteenth day of the month following the month in which the work was performed. The Fund Administrative Office permits a fifteen-day grace period to allow for mail delays. If contribution reports are not received by the 30th of the month following the month in which the work was performed, you will be subjected to liquidated damages of 10% plus 1% interest per month for each month you are delinquent to cover the additional cost and expenses of continuing administration.
What information is needed on the contribution reporting form?
To process the report correctly, the following information is needed:
The type of work (building, highway, etc.) should be marked in the box provided.
The county where the work was performed should be marked in the box indicated. This is especially important for building work as different jurisdictions have different funds that are due. If you are unsure which of the above listed funds are due under your agreement, please contact the Laborers’ Local Union in whose jurisdiction you worked for clarification.
You may report using your forms; however, all of the above mentioned information must be included, and the forms must have legible print. Reports that are difficult to read may result in unnecessary errors.
What funds are due?
The Fund Administrative Office is responsible for collecting fringe benefit contributions for the Insurance Fund, Pension Fund, Training & Upgrading Fund, LECET Fund, and LIUNA TriFunds.
If you are unsure which of the above listed funds are due under your agreement, please contact the Laborers’ Local Union in whose jurisdiction you worked for clarification.
What happens to money I sent, but which is not due your office?
If you send money to the Fund Administrative Office for Laborers’ District Council or the Ohio Contractor’s Association dues, the money is forwarded to those offices.
If, for any reason, you need a refund of Laborers’ District Council dues, the Fund Administrative Office must obtain permission from Laborers’ District Council. A refund of Ohio Contractor’s Association dues cannot be done through the Fund Administrative Office. You must contact the Ohio Contractor’s Association for a refund.
If the Fund Administrative Office receives money for other funds, such as union dues, savings, building trades, or regional LECET, we will return the money to your office. If you have questions concerning where to pay a fund owed, please contact the Laborers’ Local in whose jurisdiction you worked.
How do I report benefits for work performed outside of the jurisdiction of the Collective Bargaining Agreement?
Work performed outside the jurisdiction of the Collective Bargaining Agreement must be reported to the Fund Office in whose jurisdiction you performed the work. The Fund Administrative Office has reciprocity agreements with several states, which would allow laborers to transfer their Pension and Insurance hours to this Fund. Please contact the Enrollment Department at this office to obtain the necessary forms. This does not apply to contractors operating under an International agreement.
Why do I have to pay on non-union employees?
The Collective Bargaining Agreement states that fringe benefit contributions must be paid on all employees who perform work in a laboring capacity. Federal Law prohibits discrimination between union and non-union laborers. If the employee qualifies for benefits, the employee would have the rights and privileges under the Plan regardless of his union membership status.
Why is my company being audited?
Our organization is required by Federal Law to verify the accuracy and completeness of your monthly contributions to the Funds. There are two (2) types of audits, “routine” and “for cause.
”A “routine” will be assigned every three years to insure that a contractor is in compliance with their reporting practices. A new contractor can expect to be audited within the first signatory year for the same reason.
A “for cause” audit will be assigned due to a number of reasons. Delinquency, and unpaid shortages, liquidated damages and interest are two (2) of the main reasons.
Who are eligible individuals for medical coverage under the OLDC‐OCA Insurance Fund?
Generally, once a member has worked at least 450 hours in a six‐consecutive‐month period, the member is eligible for insurance benefits on the first day of the following month (see the Fund’s Summary Plan Description for further requirements).
Is there a waiting period for this coverage?
While there is a period of time in which a member must meet the initial eligibility requirements, there is not a “waiting period” that would be a violation of ACA rules.
What dependents are eligible for coverage?
Upon receipt of proper required documentation, the Fund will cover a legal spouse and children up to age 26 at no additional cost.
Is the coverage provided by the OLDC‐OCA Insurance Fund affordable?
As all contributions are considered employer‐paid contributions, the member’s portion of coverage is $0. Therefore, coverage is affordable.
Does the OLDC‐OCA Insurance Fund offer coverage that meets the minimum value standard as provided for under the relevant minimum value regulations?
Yes. The Fund only provides one option for coverage and it is well above the minimum value standard for coverage.
Is the OLDC‐OCA Insurance Fund a calendar year plan?
Who can employees eligible for coverage from the OLDC‐OCA Insurance Fund contact with questions about coverage?
All questions can be directed to the OLFBP Fund Office, 800 Hillsdowne Rd., Westerville, OH, 43081. Via phone at (800) 236‐6437. Via fax at (614) 898‐9169. Via email at email@example.com. Additionalinformation can be found at www.olfbp.com.
Will the OLDC‐OCA Insurance Fund provide IRS Form 1095‐B to employees with eligibility under the Fund for the calendar year 2015?
Yes, the Fund will be issuing Forms 1095‐B to eligible participants no later than January 31, 2016.
Will the OLDC‐OCA Insurance Fund provide IRS Form 1095‐C to employees for which employers contributed to the Fund during calendar year 2015?
The guidance is clear that issuance of Forms 1095‐C are a responsibility of the employer, not the group health plan; therefore, the Fund will not be issuing these forms. The Fund has over 1,000 signatory employers. Many of these employers will not be required to issue Forms 1095‐C as they do not qualify as an “Applicable Large Employer.” However, the Fund has no way of knowing which of the signatory employers will or will not be responsible for this reporting. In addition, each employer must file a “master” Form 1094‐C with the IRS that summarizes all Forms 1095‐C issued. Most of the Fund’s signatory employers will be issuing 1095‐C’s for other trades and/or office workers as well as laborers. If the Fund issued 1095‐C’s to laborers, the Fund would have to communicate the summary information back to each employer. The Fund simply does not have the resources to undertake such a responsibility. For these reasons, it has been decided that the Fund will not offer to file Forms 1095‐C on behalf of employers.
Form 1095‐C requires reporting of information that employers will need to receive from the OLDC‐OCA Insurance Fund, including coverage periods of the employee and names, Social Security Numbers, and periods of coverage for all dependents covered by the employee. How do we receive that information?
In the Form 1095‐C Instructions presented in draft form as of August 6, 2015, the IRS clarified that employers that participate in multiemployer arrangements do not have to report coverage information:
“For reporting offers of coverage for 2015, an employer relying on the multiemployer arrangement interim guidance should enter code 1H on line 14 for any month for which the employer enters code 2E on line 16 (indicating that the employer was required to contribute to a multi employer plan on behalf of the employee for that month and therefore is eligible for multiemployer interim rule relief). For reporting for 2015, Code 1H may be entered without regard to whether the employee was eligibleto enroll in coverage under the multiemployer plan. For 2016 and future years, reporting for offers of coverage made through a multiemployer plan may be reported in a different manner.” (2015 Instructions for Forms 1094‐C and 1095‐C found at http://www.irs.gov/pub/irs‐dft/i109495c‐‐dft.pdf).
Also included in the Form 1095‐C Instructions is guidance that Part III of the Form does not need to be completed by employers that offer coverage through a multiemployer health plan:
“If an employer is offering health coverage to employees other than under a self‐insured plan, such as through an insured health plan or a multiemployer health plan, the issuer of the insurance or the sponsor of the plan providing the coverage is required to furnish the information about their health coverage to any enrolled employees, and the employer should not complete Form 1095‐C, Part III, for those employees.” (2015 Instructions for Forms 1094‐C and 1095‐C found at http://www.irs.gov/pub/irs‐dft/i109495c‐‐dft.pdf).