By Gina Lemons and MeLissa Crockett
Reporting requirements change beginning 2016 under the Affordable Care Act (ACA). How these reporting requirements apply to the employer is dependent primarily on the number of employees. Employers with more than 50 full-time employees (FTEs) are considered Applicable Large Employers. Whereas, employers with fewer than 50 FTEs are considered Small Employers.
The various forms that employers may need to file with the IRS reflecting adherence with health care reform’s “shared responsibility” mandate to provide affordable health coverage to their employees are detailed below.
Applicable Large Employers (those with more than 50 FTEs)
Beginning in January 2016, Applicable Large Employers (ALEs) with 50 or more full-time or equivalent (FTE) employees must report health insurance information to the IRS and furnish statements about health insurance to their employees annually.
Which Forms
- Forms 1095-C, Employer-Provided Health Insurance Offer and Coverage
- Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns
Due Dates
The Forms 1095-C along with Forms W-2 must be provided to their employees by January 31, 2016.
The Form 1094-C and copies of Forms 1095-C must be filed with IRS by February 29, 2016, if filing on paper (only allowed if filing fewer than 250 Forms 1095-C) or by March 31, 2016 if filing electronically (required if filing 250 or more Forms 1095-C).
Which Employees
All applicable large employers (50 or more FTEs) must complete this Form 1095-C for each individual who has been employed full-time for one or more months during the calendar year and must report for all of the 12 months for each employee, this includes former employees, retirees and participants on COBRA. Form 1095-C must be completed for each full-time employee whether or not the employee is participating in an employer-sponsored group health plan, and for each part-time employee who is enrolled in the employer’s self-insured health plan. Part-time employees who are not enrolled in the employer-sponsored plan do not need a Form 1095-C.
Communicate with your Employees
A communication plan is advisable in order to head off confusion. This will be the first year employees receive a Form 1095-C and a solid communication process will ensure success for the Employer and Employee.
- Communicate to all employees, including former employees and Cobra participants.
- Communicate how the employee will receive Form 1095-C (mail, electronic, etc.)
- Communicate to employees that they will be required to submit their Form 1095-C with their Form W-2 when filing their personal income tax returns.
Small employers (those with fewer than 50 FTEs)
Small employers with a self-insured health plan must complete and file
- Forms 1095-B, Health Coverage
- Form 1094-B, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns
Small employers with fully insured health plans
- Insurance companies will provide Form 1095-B, Health Coverage
Small employers with fewer than 50 FTEs who are members of a controlled or affiliated service group that collectively has at least 50 FTEs will also be required to file
- Forms 1095-C, Employer-Provided Health Insurance Offer and Coverage
- Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns
Others
Individuals who receive health coverage through the Marketplace will be provided Form 1095-A, Health Insurance Marketplace Statement from the Marketplace.
If you have questions or need assistance on your ACA reporting, please contact our Small Business Services Department.