2015 Affordable Care Act

| 10/22/2015

2015 Affordable Care Act Reporting Requirements for Large Employers

Large employers subject to the employer mandate of the Patient Protection and Affordable Care Act are required to file employee and IRS statements regarding health insurance offerings for calendar year 2015 in early 2016.

Large employers, generally defined as those with 50 or more full-time-equivalent employees, are required to provide Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage,” for each full-time employee. Although implementation of the employer mandate was delayed until 2016 for employers with between 50 and 99 employees, these employers still must file their information reporting forms for 2015.

Form 1095-C must include the following information:

  • Whether the employee is being covered by employer-provided health insurance
  • The type of health insurance coverage provided
  • The employee’s share of the lowest-cost monthly premium
  • The number of months the employee (and any family members or others covered by that employee’s policy) was covered during the calendar year

Small employers who purchase health insurance for their employees are not required to report any information. Instead, health insurance companies will be responsible for reporting the required information for employees of small employers. However, small employers that sponsor self-insured health plans will have to provide a Form 1095-B, “Health Coverage,” to each primary insured. Form 1095-B shows the months during the calendar year that the insured and family members were covered under the plan.

These information reporting forms will have filing dates identical to those of other information reporting forms (such as Forms W-2 and 1099). Forms 1095-B and 1095-C must be provided to employees by Jan. 31 of the subsequent year. The forms must be transmitted to the IRS using new transmittal forms (Form 1094-B, “Transmittal of Health Coverage Information Returns,” and Form 1094-C, “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns”) by Feb. 28 (or March 31 if filing electronically).

There also will be an electronic filing mandate similar to the mandate for filing Form W-2 electronically. Businesses that have not yet implemented a plan to comply with the reporting requirements will need to play catch-up to file on a timely basis.

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