On December 28th it was announced that large employers with reporting responsibilities under the 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 required to comply with regulations, the extension was granted. Now companies have until March 31st to furnish Form 1095-C to employees, May 31st to file paper versions of 1094-C and 1095-C and June 30th to file electronic versions with the IRS. While the deadlines have been extended, it’s critical 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; JLK Rosenberger has provided a brief summary below.
“Pay or Play” Rules Explained
The “Pay or Play” rules state that applicable large employers – employers with 50 or more full-time employees, including full-time equivalent employees – are subject to penalties if they offer health coverage to fewer than 70 percent of full-time employees and their dependents (after 2015, the 70 percent threshold changes to 95 percent) and any full-time employee who receives premium tax credits for health coverage purchased on a state or federal exchange. What’s more, even if coverage is offered to more than the 70 percent of employees, employers may still be penalized if their coverage is not maintained as a group health plan meeting the ACA’s standards for “Minimum Value” and “Affordability” as defined by federal regulators.
Required Information to Report
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 Information
- Identifying information for employer and employee such as 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 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 an employee and whether other penalty relief applies for an employee; and
- If the employer offers a self-insured plan, information about the covered individuals enrolled in the plan.
Form 1094-C Information
- Identifying information for the employer;
- Whether the employer offered coverage to 70 percent of full-time employees and their dependents in 2015 (after 2015 this threshold changes to 95 percent);
- Total number of Forms 1095-C issued to employees;
- Information about members of the employer’s controlled group;
- Full-time employee counts by month;
- Total employee counts by month; and
- Whether the employer is eligible for certain transition relief.
Compliance with the Affordable Care Act is often tricky and complex. It’s essential to work with an experienced provider who can guide you through the process. If you have questions or concerns, JLK Rosenberger wants to help! For additional information on healthcare reform reporting, please call us at 818-334-8623, or click here to contact us. We look forward to speaking with you soon!