Smart Benefits: ACA Reporting - Earlier Deadlines & the End of Transition Relief

Rob Calise,GoLocalProv Business/Health Expert

Smart Benefits: ACA Reporting - Earlier Deadlines & the End of Transition Relief

2015 marked the first year in which employers were subject to the Affordable Care Act (ACA) reporting requirements, which introduced Forms 1094 and 1095. Employers received some welcome relief last December when the IRS extended employee notification and IRS filing deadlines for the 2015 reporting year by granting an extra two months to distribute forms to employees and three months to file with IRS. But there’s no indication that there will be the same kind of relief for 2016 reporting. Accordingly, employers are well-advised to get a jump on their data collection before year-end.  

Here are a few reminders about the reporting:

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  • Employers of any size that sponsor a self-insured health plan must distribute to employees and file with IRS Form 1095-B, showing health plan enrollment.
  • Applicable large employers with 50 or more full-time employees, including full-time equivalents, must distribute to full-time employees and file with IRS Form 1095-C. 
  • For IRS filings, Forms 1095-B and 1095-C are accompanied by transmittal forms 1094-B and 1095-B, respectively. 

 

The extended reporting deadlines are not the only relief that’s ending. Also ending in 2016 is the Section 4980H Transition Relief, which exempted medium-sized employers (those with 50-99 full-time employees, including full-time equivalents) from penalties for the 2015 plan year if certain conditions were met.  Large employers (those with 100+ full-time employees, including full-time equivalents) were also treated as offering coverage to all of their full-time employees for a month in which they offered coverage to just 70% of those employees for the 2015 plan year. 

Due to the phasing-in of the ACA’s employer mandate, medium and large employers can be subject to penalties for the 2016.

Rob Calise is the Managing Director, Employee Benefits. of Cornerstone|Gencorp, where he helps clients control the costs of employee benefits by focusing on consumer driven strategies and on how to best utilize the tax savings tools the government provides. Rob serves as Chairman of the Board of United Benefit Advisors, and is a board member of the Blue Cross & Blue Shield of RI Broker Advisory Board, United HealthCare of New England Broker Advisory Board and Rhode Island Business Healthcare Advisors Council. He is also a member of the National Association of Health Underwriters (NAHU), American Health Insurance Association (AHIA) and the Employers Council on Flexible Compensation (ECFC), as well as various human resource associations. Rob is a graduate of Bryant University with a BS in Finance.

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