The IRS Issues Forms Specific to ACA Reporting for Employers
The IRS issued the last forms on February 8, 2015. They have issued both 1094-C and 1095-C for 2014. Employers will use these forms to report coverage offered under health insurance employer-sponsored plans as required by the Internal Revenue Code on Section 6056. They have also issued the final instructions which did have some noteworthy revisions from an otherwise unchanged form from draft.
Requirements of the IRC Code
Under the IRC Code Section 6056, applicable large employers are required to report to the IRS whether they offer minimal essential coverage to full-time employees and their dependents. If the employer has an average of 50 full-time workers or more, then they are applicable. If an employee works at least 30 hours a week, they are full-time. If the employee otherwise works at least 130 hours a month, he is considered full time.
Full-Time Employees Identified by Form
Form 1095-C is used to find out who was working full-time for a company for at least one month. Each month will be reported with details of health care coverage. Employees must be given the 1095-C by January 31, 2014 for 2015. The forms are to be filed with the IRS as it relates to the deadlines for W-2.
Form 1095-B identifies all of the covered people and their coverage months. Insurers and health care providers will fill out forms 1095-B in order to report every individual who is insured to the IRS. ALEs that are self-insured will issue and file reports 6055/6056. The third part of Form 1095-C deals with the reporting elements of Section 6055. Form 1095-C arranges the information in three rows for each full-time employee by the month.
The First Row
The first row deals with whether or not the ALE offered MEC to his employees and any family or dependent. The dependents and spouse must be qualified to receive the coverage. The provided coverage must have the minimum value.
The Second Row
The second row is where the share of the employees monthly premium when it comes to self only coverage. This is often the lowest cost monthly premium service plan. There are no dependents on this health insurance plan.
The Third Row
The third row deals with whether or not the employer may have a shared responsibility payment. One example of this is the identification of employees who did not work full-time. There are codes that deal with the relief known as a “safe-harbor”.
Noticeable Revisions to Instructions
Among the noteworthy revisions is coverage for non-employees. The draft instructions have stated that the self-insured ALEs could use 1095-C in order to satisfy the reporting obligations of sections 6055 and 6056. The final instructions allow for use of 1095-B as well as C for reporting.
Self-insured employers are required to report on anyone who signs up for a plan sponsored by an employer. It doesn’t matter whether or not the person is a full time employee. 1095-C is going to be required for employees who work part-time. Non-employees that are covered need to fill out the same form.
ALEs can file more than just one Form 1094-C transmittal. They just have to make sure that the one transmittal is made to be the authoritative transmittal. It is clear in the final instructions that the authoritative transmittal reports are the only ones that report details for the ALE. The other transmittal forms should leave everything blank.
ALEs are required to report the total number of their employees. There are two methods of counting for drafts. The employees could either be counted on the first day of each month or the last day of the month. The final draft of these instructions allow for the first or last day counting of first payroll period of the month.
Full-Time Employee Numbers
The employees are clarified to not be full-time employees if they are in Limited Non-Assessment Periods. They are not to be included in the number of full-time employees being reported. Forms 1095-C require employees in Limited Non-Assessment Periods to be reported with Code 2D for the 16th line on any month which has the employee on this designation.
Deemed Coverage Offer
ALEs can offer certain employees some coverage in the case that there is no actual coverage offered. This is reported on Part 3 of Form 1094-C. According to the final instructions, ALEs can only report actual offers of coverage on Form 1095-C. Each ALE has the responsibility and liability for reporting with the option of using a third party.
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