Do you have a plan for collecting the employee data required for filing IRS forms 1094-C and 1095-C?
The ACA imposes significant and complex reporting responsibilities on employers starting with the 2015 calendar year. The new reporting requirements are similar to the current Form W-2 reporting in that an information return (Form 1095-B or 1095-C) will be prepared for each applicable employee, and these returns will be filed with the IRS using a single transmittal form (Form 1094-B or 1094-C).
ACA Reporting Requirements
The ACA created new reporting requirements for employers about the health plan coverage they offer (or do not offer) to their employees. The requirements help the IRS administer several provisions under the ACA, including the Employer Shared Responsibility Penalty and the Individual Shared Responsibility Mandate.
Specifically, the IRS will use information reported by employers to determine:
- Employees eligible for subsidies to purchase coverage through the Exchange (Marketplace)
- Employees without Minimum Essential Coverage (MEC) that are subject to Individual Shared Responsibility Penalty
- Large employers that fail to offer Minimum Essential Coverage (MEC) to full-time employees may be subject to penalties (See Appendix F: Penalties – Penalty “A”)
- Large employers that fail to offer Minimum Value Affordable Coverage to full-time employees and may be subject to penalties. (See Appendix F: Penalties – Penalty “B”)
There are two types of ACA reporting:
- Health insurance providers and sponsors of self-insured plans are required to report on the health coverage offered.
- Employers categorized as an Applicable Large Employer (ALE), for employing at least 50 full-time employees including Full-Time Equivalents (FTEs) during the preceding calendar year, must report on terms and conditions of Health Coverage offered to all full-time employees.
The reporting requirement first applies for calendar year 2015 with reports due in early 2016:
- 2015 Form 1095-C (employee statement): Due February 1, 2016
- 2015 Form 1094-C (transmittal form with copies of Forms 1095-C): Due February 29, 2016 or March 31, 2016, if filing electronically. Employers must file electronically if more than 250 1095-C forms are being submitted.
The due dates are the same as the due dates for Form W-2 for the same calendar year. If the due date falls on a weekend or legal holiday, the employer may file by the next business day.