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As we begin a new year, this is a good time for a quick reminder about the Form 1094 and 1095 employer reporting requirements under the Affordable Care Act. The deadline for the 1095 reports that must be provided to your employees has been extended to March 2, but the deadline for filing the required paperwork with the IRS remains February 28 for paper filings or April 2 if you file electronically. Answers to commonly asked questions can be found below.

Which employers are subject to the reporting requirements?

There are two sets of reporting requirements: one for self-insured employers regardless of size, and a second for Applicable Large Employers (ALEs). ALEs normally have 50 or more full-time equivalent employees (FTEs), but a company with fewer than 50 FTEs can still be considered an Applicable Large Employer if it’s part of a larger controlled group.

If your company is under common ownership and the total combined number of full-time equivalent employees is 50 or higher, then you are considered to be an ALE. This makes you subject to the employer mandate and the employer reporting requirements.

Fully-insured companies with fewer than 50 FTEs are not subject to the employer reporting requirements.

What are the reporting requirements?

There are two sets of reporting requirements under the Affordable Care Act:

  • One requires that you provide your employees with information about the coverage they were offered and that they enrolled in on Form 1095C (see chart below).
  • The second requires that you provide the IRS with information about the health coverage you offered to your employees on form 1094C (see chart below). You’re also required to provide the IRS with copies of the 1095 C employee forms. The government uses this information to enforce the employer and individual mandates and to determine eligibility for the premium tax credits.

This chart should help you determine which forms, if any, you’re required to file.

What are the reporting deadlines?

The deadlines can be found in the chart above, but here they are again with some additional information.

  • FORMS TO PROVIDE TO YOUR EMPLOYEES: The deadline for the reports due to individuals has be extended to March 2 (the original deadline was January 31), but employers are encouraged to provide the forms to their employees as soon as possible since they’ll need this information when filing their 2017 tax returns.
  • FORMS TO PROVIDE TO THE IRS: The deadline for filing the required forms with the IRS remains February 28 if you file by paper or April 2 if you file electronically.

What if I need help completing the forms?

You may already be working with a CPA, Third-Party Administrator (TPA), or payroll company to help you complete the required employer and employee paperwork, but if not we can refer you to a TPA that we work with. This administrator has helped a number of our clients in the past (we do not take a commission for the referral) and also provides ERISA documents and other administrative services you may be interested in. Please let us know if you’d like to learn more.

For more information, please refer to the employer page of the website. It has a number of articles and other resources that help to explain the mandate and the reporting requirements. For example, here’s a link to a webinar we did about the reporting requirements that might answer some of your questions. You may also want to read the IRS notice about the 2017 reporting requirements and deadlines.

Is the IRS actually enforcing the employer mandate?

Yes! The IRS recently started sending out letters to Applicable Large Employers that might owe a penalty under the ACA’s employer mandate. We’ve heard stories about Applicable Large Employers that have stopped offering coverage or stopped filing the required paperwork with the hope that the employer mandate or reporting requirements will be repealed. This is a mistake. For now, nothing has changed. The individual mandate penalties will go away starting in 2019, but ALEs are still required to offer coverage to their full-time employees, and companies are still required to complete the employer reports. Failing to do so could result in big penalties.

We hope you find this information beneficial, but if you have any questions please let us know.

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