ACA Reporting Due Early 2017

ACA DeadlinesBy Michael Berwanger, JD, Director, Quality Management & Compliance

In early 2017, employers and insurance carriers must report information to employees and the IRS about coverage offered to employees under employer-sponsored health plans during calendar year 2016.

Background

The Patient Protection and Affordable Care Act (ACA) requires self-funded employers to satisfy two reporting obligations under Sections 6055 and 6056 of the Internal Revenue Code, relating to health coverage offered to employees and about those employees who are covered under the plan.

The purpose of the reporting obligations is to allow the IRS access to data needed to monitor compliance with both the employer and individual mandates. The reporting also may be used by affected employees in assessing their own compliance with the individual mandate and/or in seeking subsidized coverage on the federal and state exchanges established under the ACA (as described in this blog post).

Section 60ACA reporting55 Reporting Compliance

Under Section 6055 of the Internal Revenue Code, all self-funded employers must annually report information to the IRS and to any individual who is covered under a health plan offered by the employer.

Currently, many employers do not have access to Social Security numbers for non-employed dependents, creating a fairly significant compliance burden to collect that data. The regulations require that employers exercise “reasonable collection efforts” to obtain that information. (Typically, an employer will satisfy that standard by documenting at least two efforts to request the data from those individuals). This same information must be reported to employees, along with basic contact information for the employer.

Section 6056 Reporting Compliance

The second reporting obligation, under Code Section 6056, applies only to “Applicable Large Employers.” Applicable Large Employers are those employers with at least 50 full-time equivalent employees and to whom the ACA’s employer mandate applies.

Unlike Section 6055 reporting, all of this information also must be provided separately to each employee, full-time, part-time, or otherwise. You can read helpful IRS guidance about 6056 reporting here.

IRS Forms 1094 and 1095

The compliance obligations are complex, and the IRS has developed forms (Forms 1094-B, 1095-B, 1094-C, and 1095-C) to provide consistency in reporting and to help simplify the process for employers.

Applicable Large Employers (ALEs) who offer coverage under a self-funded health plan may use Form 1095-C, which combines the reporting obligations of Sections 6055 and 6056 in a single form for reporting to both the IRS and individuals. When the forms are provided to the IRS, the Applicable Large Employer also must submit a transmittal form, Form 1094-C. Forms 1095-C and 1094-C, along with instructions, can be accessed here.

Small employers with fewer than 50 full-time equivalent employees are only required to meet one of the reporting obligations, the Minimum Essential Coverage reporting under Section 6055. Small employers may use Form 1095-B, with transmittal Form 1094-B. These forms, along with instructions, can be accessed onACA reporting the IRS web site here.

Changes from reporting year 2015 to 2016 for forms 1094-C and 1095-C can be found here.

Changes from reporting year 2015 to 2016 for forms 1094-B and 1095-B can be found here.

Compliance Deadline

Filings will begin in early 2017 for the 2016 calendar year.

*Form 1095-C must be provided to all employees (full-time, part-time, or otherwise) by March 2, 2017.

*All Forms 1095-C, along with the transmittal form, 1094-C, must be provided to the IRS by February 28, 2017 (if in paper form), or March 31, 2017 (if filed electronically). 

Note: Employers filing more than 250 information returns (Form 1095-C) must do so electronically.MedCost

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IRS Extends Due Dates for New 2015 Reporting

Tax form & glassesOn Dec. 28, the IRS extended the due dates for new health care information reporting forms in 2016. Insurers, self-insuring employers, other coverage providers, and applicable large employers now have additional time to provide health coverage information for 2015 to individual taxpayers and the IRS. Providers and certain employers must now furnish individuals with either Form 1095-B or 1095-C by March 31, 2016. The due dates for issuers filing these forms and the associated Form 1094 with the IRS are May 31, 2016, for paper filers and June 30, 2016, for electronic filers.

Individual taxpayers will generally not be affected by this extension and should file their tax returns as they normally would. However, due to these extensions, some individual taxpayers may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2015 tax return. While the information on these forms may assist in preparing a return, they are not required. Like last year, taxpayers can prepare and file their returns using other information about their health insurance. Individuals do not have to wait for their Form 1095-B or 1095-C in order to file.

These extensions apply automatically to all health coverage information return issuers and are longer than the 30-day extensions that would otherwise be obtained by submitting Form 8809, Application for Extension of Time To File Information Returns. Therefore, the IRS will not process any previously requested extensions of these deadlines for 2016. The longer automatic extensions do not require a formal request using Form 8809 or other documentation. The IRS does not anticipate additional extensions.

The IRS has not extended the due dates for Health Insurance Marketplaces to issue Form 1095-A. Individuals who enrolled for coverage through the Marketplace should receive Form 1095-A by February 1, 2016, and should wait to file their returns until they receive their Form 1095-A.

 For more information: https://www.irs.gov/Affordable-Care-Act/IRS-Extends-Due-Dates-for-New-2015-Information-Reporting-Requirements

How to Fill Out IRS Forms 1094/1095

By MedCost General Counsel Brad Roehrenbeck, JD

1094-C tax form

Employers heard some good news when the Internal Revenue Service (IRS) extended deadlines for reporting 2015 forms 1094/1095 (see “IRS Extends Deadline for 2015 ACA Reporting”).

Concerned about meeting this first year of Affordable Care Act (ACA) reporting requirements? MedCost General Counsel Brad Roehrenbeck gives step-by-step instructions about how to fill out IRS forms 1094 and 1095 in a free webinar offered here.

Small self-funded employers (those with less than 50 full-time equivalent employees) are only required to meet one of the two ACA-mandated reporting obligations. Specifically, small self-funded employers must meet the Minimum Essential Coverage (MEC) reporting obligation, by reporting on individuals to whom they have provided health coverage during 2015 using Forms 1094-B and 1095-B.

On the other hand, Applicable Large Employers (ALE)—those with more than 50 full-time (equivalent) employees—must report additional information beyond that included in the MEC reporting required of small employers. The IRS has developed a single set of forms (Forms 1094-C and 1095-C) that can be used by Applicable Large Employers to meet all of their reporting requirements.

These ACA-mandated reporting obligations are designed to document compliance with the Affordable Care Act’s two flagship mandates – the individual and employer mandates.

DeWebinar buttonadlines are soon approaching to file these forms. For more information, watch this webinar on 1094/1095 reporting.