The Patient Protection and Affordable Care Act (PPACA), or simply the Affordable Care Act (ACA), is the new healthcare reform law. The Affordable Care Act represents the most profound regulatory change to the federal healthcare system in the United States since Medicaid and Medicare.
What’s New for Large Employers and the Affordable Care Act (ACA)
Going into 2016, the IRS is reaffirming that two key provisions of the Affordable Care Act (ACA), that only apply to “applicable large employers” or ALEs, are now in effect:
- The employer shared responsibility provision and
- The employer information reporting provision for offers of minimum essential coverage
The IRS Extends Due Dates for New 2015 ACA Information Reporting Requirements
On Dec. 28, the IRS extended the due dates for new health care information reporting forms in 2016. Insurers, self-insuring employers, other coverage providers, and applicable large employers now have additional time to provide health coverage information for 2015 to individual taxpayers and the IRS.
According to the IRS:
- Providers and certain employers must now furnish individuals with either Form 1095-B or 1095-C by March 31, 2016.
- The due dates for issuers filing these forms and the associated Form 1094 with the IRS are May 31, 2016 for paper filers and June 30, 2016 for electronic filers.
While the IRS is prepared to accept information reporting Forms 1094-B, 1095-B, 1094-C, and 1095-C beginning in January 2016, they have determined that employers, insurers, and other providers of minimum essential coverage needed additional time. Consequently, a three-month extension has been granted for these parties to adapt and implement systems and procedures needed to gather, analyze, and report this information.
For those who are prepared to submit the forms to employees, and file them with the IRS before the extended due date, are being encouraged to do so rather than waiting until March 31.
How to Determine if You Are an ACA “Applicable Large Employer”
According to the IRS and the definition found in the ACA, if an employer has at least 50 full-time employees, including full-time equivalent employees, on average during the prior year, the employer is an ALE for the current calendar year. (For more information on ALEs go to this IRS page)
The IRS states that you must determine your ALE status each calendar year based on the average size of your workforce during the prior year. If you had at least 50 full-time employees, including full-time equivalent employees, on average during 2014, then you are most likely an ALE for 2015. Employers that are determined to be ALEs should be taking steps now to prepare for the upcoming tax filing season.
If you will be filing at least 250 or more 1094-C information returns for 2015, you must file the returns electronically through the ACA Information Reports system. You should also review draft Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns, for additional information on the procedures, formats, business rules and validation procedures.
Notify Your Employees
Also, beginning in 2016, ALEs must provide a statement to each full-time employee.
According to the IRS, they are:
“Informing individual taxpayers that due to these extensions, they may not receive a Form 1095-B or Form 1095-C by the time they are ready to file their 2015 individual income tax return. While the information on these forms may assist in preparing a return, they are not required to file. Like last year, taxpayers can prepare and file their returns using other information about their health insurance. Individuals do not have to wait for their Form 1095-B or 1095-C in order to file.”
Final Versions of 2015 Health Care Information Reporting Forms Now Available
The IRS released the final versions of two key 2015 forms and the related instructions that employers and insurers will send to the IRS and individuals this winter to report health care coverage they offered or provided:
Essential IRS Forms and Publications
- Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
- Form 1094-C Instructions
- Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
- Form 1095-C Instructions
Keep Informed to Ensure Ongoing ACA Compliance
Accurate and timely management of and compliance with ACA requirements are critical for every business and every payroll professional. But there are options. Accuchex, a reputable payroll management services provider, can not only relieve you of the burden of your ongoing payroll process demands, but can potentially prove to be a more cost-effective solution, as well.