Time to Prepare for 2016 ACA Reporting Requirements

1/4/2017

Under Section 6055 of the Affordable Care Act (ACA), employers with self-funded health plans must report information about minimum essential coverage to assist in enforcing the individual mandate penalty.  Under Section 6056, applicable large employers (ALEs), or employers with 50 or more full-time employees and full-time employee equivalents in the prior year, must report shared-responsibility information to assist in enforcing the play-or-pay penalty and determining eligibility for a premium credit.

IRS Forms

Form 1095-C provides information about health insurance and is sent to both employees and the IRS, and Form 1094-C acts as a transmittal form/cover sheet about Forms 1095-C and is sent only to the IRS.  ALEs with self-funded plans must send Form 1095-C to all full-time employees who are credited with an average of 30 hours per week or more during the look-back measurement period, regardless of whether they elect coverage, and all non-full-time employees who enroll (as well as any enrolled non-employees, such as retirees).  This statement provides details about the coverage offered, the lowest-cost premium available to the employee for single coverage, and the months of the year when the coverage was available.  Employers must send the Forms 1095-C to the IRS as well, and when they do, they also file Form 1094-C for transmittal.  Form 1094-C provides information about the employer, the number of employees, the name of a contact person, and the number of forms being sent.

Small employers (those not subject to the employer shared-responsibility provisions) with self-funded health plans will file Form 1095-B with employees and the IRS to report individuals who are covered by minimum essential coverage.  Form 1094-B is the transmittal form that must be filed with the Forms 1095-B to the IRS.

Deadlines

ALEs must furnish the Forms 1095-C reflecting 2016 information to employees by March 2, 2017 (extended deadline).  Reporting Forms reflecting 2016 information are due to the IRS by February 28, 2017, or March 31, 2017 if submitted electronically.  Employers that are required to file at least 250 Reporting Forms must file electronically, although the IRS encourages all employers to file electronically.

Assistance from ASR Health Benefits

In order to assist clients in submitting Reporting Forms, ASR provides data via our Website to complete Part I Employee and Part III Covered individuals of Form 1095-C.  To access your data, log on to the ASR Website at www.asrhealthbenefits.com and follow these steps:

  1. Select Report Dashboard under the REPORTS item of the main menu, and then select either 1095 Extract – Row Per Enrollee or 1095 Extract – Row Per Member (under Additional category). You will be directed to the 1095 Extract page.  NOTE:  The report option that displays data per enrollee may accommodate some third-party software applications employers may use to complete the Reporting Forms.
  2. Select either Month/Year or Year and the desired date, and click on the Get Report
  3. Print the file or download it to Excel. Please note that the spreadsheet provided by ASR is not intended to be uploaded into the IRS’s Website as part of the filing process.

Penalty

The penalty for failure to file Reporting Forms is $250 per return, and the maximum amount that can be imposed is $3,000,000.  The penalty applies to both the Reporting Forms filed with the IRS and the statements provided to individuals.  However, for the 2016 reporting year, the IRS has extended transition relief from penalties for incomplete or incorrect filings where the employer acted reasonably and in good faith.

If you have questions, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.

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