The Time is Here: Reporting Requirements for Applicable Large Employers
Under the health care law, applicable large employers (ALE) – those with 50 or more full-time employees, including full-time equivalent employees, in the preceding year – are required to report some information regarding health coverage by filing information returns with the IRS and furnishing statements to full-time employees.
If you’re an ALE, you report information about health coverage you offered to each full-time employee, or to show that you didn’t offer coverage to the full-time employee. This information will help the IRS determine whether an employer shared responsibility payment applies to your organization and is also used in determining the eligibility of employees for the premium tax credit. Here are some key points about the information reporting requirements for ALE’s under the health care law:
- You are required to report certain information to the IRS, as well as to all of your full-time employees, regardless of whether you offer health insurance coverage.
- Your first information reporting returns are due in 2016 for the year 2015.
- There are new IRS forms that ALEs will use to complete this reporting.
- You are required to furnish each full-time employee with a statement, Form 1095-C, by January 31.
- You must file the information returns Forms 1094-C and 1095-C with the IRS no later than Feb. 28 – or March 31 if filed electronically.
- If you’re an ALE that sponsors a self-insured group health plan for your employees, you also must report information about employees and their dependents who enroll in the coverage, whether or not the employee is a full-time employee.
New IRS Resource helps Employers Understand the Health Care Law
The new ACA Information Center for Applicable Large Employers page on IRS.gov features information and resources for employers of all sizes on how the health care law may affect them if they fit the definition of an applicable large employer.
Final 2015 Health Care Reporting Forms are Now Available
The Internal Revenue Service has 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. The IRS released draft forms and instructions for 2015 this summer and the final forms and instructions for 2015 are largely unchanged from the previously released drafts.
The 2015 version of Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, used by employers with 50 or more full-time employees are now available on IRS.gov. Form 1095-B, Health Coverage, primarily used by insurers and health coverage providers, including employers that sponsor self-insured plans, is also available on IRS.gov.
What to do next
While Congress has put the oversight with the IRS and the reporting obligations on the employer, it is important you consult your health insurance provider and begin gathering the necessary information at your earliest convenience. If we can be of assistance to you in assessing your reporting obligations, please do not hesitate to contact us at (231) 726-5800 or (616) 608-8500.