Year-end 2015 will bring new reporting requirement for employers for the Affordable Care Act (ACA). You may think this reporting only applies to organizations subject to the Employer Mandate (otherwise known as “Applicable Large Employers” (ALEs)) – those with over 50 full-time-equivalent employees (FTEs), but that’s not necessarily the case. Even small employers may have to comply with these reporting requirements if their group health plan is self-funded.
Here’s how you can keep these complicated reporting requirements straight. There are two kinds of forms – the “B” forms (1094-B and 1095-B) and the “C” forms (1094-C and 1095-C). An easy way to look at ACA reporting is by considering it similar to wage reporting using Form W-2. The “C” forms are sent out to each employee reporting their insurance coverage, much like W-2s are used to report wages. The “B” forms summarize the underlying “C” forms, much like Form W-3 summarizes all the wage statements.
The “B” forms must be filed by:
- Insurance Companies
- Employers who are NOT Applicable Large Employers who are sponsors of self-funded health plans. This means that small employers who are not subject to the employer mandate but are self-funded are subject to this reporting.
The purpose of the “B” forms is to report individuals who are covered by minimum essential coverage so that they won’t be penalized for not having insurance.
The “C” forms are only filed by Applicable Large Employers (ALEs), regardless of whether the employer sponsors a group health plan, whether it is fully insured or self-funded, and even if the ALE is exempt from the employer mandate. The purpose of these forms is to report insurance offers and coverage for employees, to determine whether employers owe a penalty, and to determine employee eligibility for the premium tax credit.
Here’s a simple chart outlining the reporting requirements for different organizations:
When to File
Regardless of which form you’re required to file, they’re due to employees by February 1, 2016 (normally January 31, but it’s a Sunday); and to the government by February 29, 2016 if you’re filing by paper or by March 31, 2016 if filed electronically.
If you’re a Mize Houser payroll client, we’re ready to assist you in this reporting, but will need you to provide the following information:
- Is your group health plan fully insured or self-insured?
- Do all employees in your payroll database have current dates of birth, hire and termination?
- Have you maintained up to date information for individuals covered by your group policy, such as the date you offered insurance, the effective date of coverage, and the effective date of any individuals who are no longer covered by your plan?
- The names and coverage information for individuals covered by your group plan who may not be included on the payroll system, such as owners.
- For self-insured plans, the dates of birth and social security numbers for dependents covered under the group plan.
We’re here to help – please contact your Mize Houser payroll processor for more information.