Obamacare Extension Provides Reporting Relief

January 20, 2016

According to an announcement late last month, large employers with reporting responsibilities under the Affordable Care Act’s “pay or play” provision would receive relief in the form of filing extensions. Due to the complexity of the reporting and sheer amount of work it will take some companies to comply with regulations, the extension was granted. Now companies have until March 31 (versus February 1) to furnish Form 1095-C to employees, May 31 (instead of February 29) to file paper versions of 1094-C and 1095-C with the IRS and June 30 (versus March 31) to file electronic versions with the IRS. Although the deadlines have been extended, it’s critical that companies are aware of their reporting responsibility and what steps they need to take to maintain compliance. To help clients, prospects and others understand the requirements, Wilson Lewis has provided a brief summary below.

 

Required Reporting

 

The IRS requires specific information to be reported for each of the two types of forms that must be filed. Below is a rundown of information applicable large employers must report for each month in 2015:

Form 1095-C Reporting Requirements:

  • Identifying information for the employer and employee, including name and address

  • Whether the employee was full-time

  • Information about the health coverage, if any, offered to the employee

  • The employee’s share of the monthly premium for the lowest-cost, self-only minimum value coverage

  • Months the employee was enrolled in coverage

  • Months the employer met an affordability safe harbor with respect to the employee and whether other penalty relief applies for the employee

  • If the employer offers a self-insured plan, information about the covered individuals enrolled in the plan

Form 1094-C Reporting Requirements:

  • Identifying information for the employer

  • Whether the employer offered coverage to 70 percent of full-time employees and their dependents in 2015

  • Total number of 1095-C forms issued to employees

  • Information about members of the employer’s controlled group

  • Full-time employee counts by month

  • Total employee counts by month

  • Whether the employer is eligible for certain transition relief

     

     

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