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Filing Requirements for ACA Form 1095-C

01/25/2019

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By Terri Mangrum, guest blogger

The IRS has granted employers an extension for mailing ACA forms, thus providing a little breathing room for those involved in preparing the forms.

1/25/19: Taxpayers may claim additional Affordable Care Act hardship exemptions without certification. In recent guidance, the IRS identified exemptions from the Section 5000A individual shared responsibility payment that may be claimed on federal tax returns for the 2018 tax year. They may be claimed without obtaining an exemption certificate from the Health Insurance Marketplace. A taxpayer is eligible for such an exemption for at least the month before, the months during, and the month after the eligible events occur. Read Notice 2019-05.

1/14/19: The IRS has announced that electronic filing of Affordable Care Act (ACA) information returns (Forms 1094 and 1095) for the 2018 tax year will become available on 1/15/19, at approximately 9 a.m. Eastern time. The tax code requires information reporting on these forms by health coverage providers and applicable large employers (ALEs). Electronic filing through the ACA Information Returns (AIR) Program is mandatory for providers and ALEs transmitting 250 or more individual information returns. For more information visit the IRS website for ACA

11/29/18: Employers are granted an extension to furnish 2018 Affordable Care Act (ACA) forms to recipients. Health insurers and health plan sponsors must give all covered individuals an annual information statement summarizing their health care coverage. The deadline to furnish individuals with 2018 Form 1095-B and Form 1095-C is now extended, from 1/31/19 to 3/4/19. No extension is granted for filing forms with the IRS. This deadline remains 2/28/19, or 4/1/19 if filing electronically. Late filing may result in penalties. (IRS Notice 2018-94)

Who Must File the ACA Form 1095-C?

As most business owners are now aware, under the ACA Employer Shared Responsibility Provisions, employers who average more than 50 full-time plus full-time equivalent employees during the previous calendar year must prepare and mail a Form 1095-C to each full-time employee. Although the form is not required for tax filing purposes, it can be viewed as the W-2 for medical insurance coverage.

How to Know if You Are Required to Provide the Form 1095-C

An employer must first determine if they are required to provide the Form 1095-C to their employees. This determination involves a specific formula for counting the employees. Additionally, other variants must be considered such as seasonal employees, variable hour employees, and understanding the IRS’s definition of a full-time employee.

What does the Form 1095-C Include?

The Form 1095-C reports the monthly offer of qualifying medical coverage (or the lack of), employee eligibility, enrollment or waiver decision, affordability of the monthly premium to the employee, and the employee’s employment status. Complicating this bounty of required information, the IRS has established a complex system of codes used to describe each of these reporting elements.

To sum it up, preparing the Form 1095-C entails the understanding of the intricate requirements, definitions, formulas, and reporting codes of the provisions. The process can involve payroll vendors to determine an employee’s full-time status and affordability of coverage, as well as benefits or human resources departments for identifying offers of coverage, cost of coverage, and enrollments.

How Can LBMC Employment Partners, LLC, Help?

This is a substantial task for a business owner who would prefer to spend his or her time running the business. LBMC Employment Partners, LLC, can help with this filing requirement, including calculating the number of employees, confirming if a filing is required, as well as preparing and mailing the forms to employees.

If you need assistance with your ACA Employer Shared Responsibility requirements, call Rebekah Harney at 615-309-2262. She can start the process of helping employers comply with the ACA Form 1095-C provision, or contact LBMC Employment Partners today to learn more!

Original Post: 2/15/18; Updated 1/14/19