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Applicable Large Employers ACA Reporting Requirements

02/18/2016  |  By: Brian McCuller, JD, CPA, Shareholder, Practice Leader Tax

The Affordable Care Act has arrived and the first reporting requirement will be in early 2016 for the 2015 calendar year.

For furnishing employees with the 2015 Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage), the deadline has been extended from Feb. 1, 2016, to March 31, 2016.

For filing with the IRS the 2015 Form 1094-B (Transmittal of Health Coverage Information Returns), Form 1095-B, Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and Form 1095-C, the deadline has been extended from Feb. 29, 2016, to May 31, 2016 if not filing electronically, and from March 31, 2016, to June 30, 2016 if filing electronically. Any employer filing 250 or more information returns during the calendar year must file the returns electronically. For employers with fewer than 250 returns, electronic filing is voluntary.

To meet the impending reporting requirements under the ACA, employers should consider the processes they will need to have in place in order to collect and report the required information. Unfortunately, this data collection isn’t an easy task.  It can require various internal departments to “connect” and share information.  Employers must also be keenly aware of the number of hours worked by each employee as well as the ACA classification of each employee.  ACA compliance also necessitates that an employer review its group medical plan to verify that the offered plan meets the required minimum value standard and is affordable to its employee population.

The size of your company does make a difference.  Employers with less than 50 full-time and full-time equivalent employees are considered a small employer and are not subject to the ACA reporting for 2015. Employers with 50 or more full-time and full-time equivalent employees during the year are considered an “Applicable Large Employer” (ALE) and are subject to the ACA reporting for 2015. Relief will soon follow due to a change in the definition of an ALE in 2016.  Following the change, only employers with 100 or more full-time and full-time equivalent employees will be considered an ALE and subject to the ACA reporting. In order to ensure ongoing compliance, maintaining reliable and consistent records of your payroll and benefits information is a necessity. A complete audit trail of all information utilized should be maintained and easily accessible in the event of a federal inquiry or an assessed ACA penalty.

LBMC Employment Partners, LLC can assist you with all your ACA needs!   We are currently assisting clients with identifying and gathering the data necessary to determine an employer’s and employee’s ACA status, as well as preparing the annual Forms 1094/1095-C. Applicable Large Employers must report various benefit and payroll activity, and we can guide you along the way. We understand the reporting requirements and how information should be retained and submitted.  Both small and large employers benefit from our ACA consulting services.  Please review our outline of the ACA services we provide and how we can assist you. 

Let our team know if you would like to schedule a meeting to discuss your ACA compliant plan of action.  Again, it is not an easy task and because reporting requirements require you to go back to January 2015, it is important to start the process as quickly as possible to avoid year-end resource constraints.