2016 has arrived and new reporting requirements under the Affordable Care Act are in effect. In this blog post we’ll cover the new Forms for 2015 so you’re educated on complying with the new Affordable Care Act reporting requirements
Form 1095-B Health Coverage
Form 1095-B reports the month(s) an insured individual and their family (if applicable) was covered under an employer sponsored plan. This helps in determining whether or not affordable coverage was offered to each individual employee during the year. The individual employee uses information on this Form when filing their individual income tax return.
Insurance companies of employer sponsored health insurance plans are responsible to issue Form 1095-B to employees. Self-insured employers with less than 50 full-time are responsible to issue this Form. Self-insured small employers should check with their third party administrator to verify who will be providing this Form to employees. The deadline to furnish this Form to employees is March 31, 2016. The Form is also due to the IRS May 31, 2016 if filing by paper, or June 30, 2016 if filing electronically.
Form 1094-B Transmittal of Health Coverage Information Returns
Form 1094-B is simply a summary of the information transmitted on Form 1095-B. The Form is due May 31, 2016 if filing by paper, or June 30, 2016 if filing electronically. Form 1094-B accompanies the filing of Form 1095-B.
Form 1095-C Employer-Provided Health Insurance Offer and Coverage
Form 1095-C is prepared by Applicable Large Employers (employers with 50 or more full-time equivalents), both insured and self-insured. This Form provides full-time employees (part-time and seasonal employees will not receive this Form) with coverage information offered to them during the year. The Form is due to the IRS May 31, 2016 if filing by paper, or June 30, 2016 if filing electronically. The deadline to furnish this Form to employees is March 31, 2016.
Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
From 1094-C accompanies Form 1095-C and details whether or not the employer offered health coverage to employees. The difference between Form 1094-C and 1095-C is that 1094-C provides information to the IRS on the employer as a whole, whereas Form 1095-C provides information to the individual employee on coverage offered to them. The Form is due to the IRS May 31, 2016 if filing by paper, or June 30, 2016 if filing electronically. Form 1094-C accompanies the filing of Form 1095-C.
Form 1095-A Health Insurance Marketplace Statement is sent only to individuals who enroll in a health insurance plan through the marketplace (regardless of whether or not they received a subsidy). Employers will not fill out this Form. Employers with over 250 w2’s are required to file their w2’s electronically and report the total premium amount on each individual employee’s w2.
There is no additional penalty calculation Form or declaration of offering Form that will be reported to the IRS. Many small employers (under 50 full-time employees) wonder if they have any reporting requirements. Some ask “is there some way to notify the IRS to let them know I am not an applicable large employer?” The answer is no, there is not. The IRS is treating this as an “on your honor” system and the approach is that any penalties will be calculated by the IRS and notification sent separately based on the information reported on forms 1094-C and 1095-C.
The Affordable Care Act is extremely complex and a single approach to each situation is not adequate. For specific information on your situation, please contact your CPA at Cook Martin Poulson.