Important Update Regarding Affordable Care Act Information Returns (AIR)

Effective January 1, 2015, under the Affordable Care Act (also known as ObamaCare), employers with 50 or more full-time equivalent employees on average during 2014, are considered Applicable Large Employers (ALEs) and are required to comply with new provisions and reporting requirements. They include:

Employer Shared Responsibility Payment – Offer insurance to qualifying full-time employees and their dependents. However, ALEs with fewer than 100 full-time equivalent employees in 2014, that meet certain conditions, are not subject to the employer shared responsibility payment in 2015.
Employer Information Reporting – Report on the health coverage offers and enrollment, pertaining to full-time employees. (Applicable to all ALEs without exception)
Provider Information Reporting – Report information about employees and their dependents who enroll in the coverage, whether or not the employee is a full-time employee. (Applicable to “self-insured” ALEs – employers who sponsor self-insured group health plans)

Regardless of workforce size, any employer who provides self-insured health coverage will have a filing requirement

Even an ALE that is not liable for an employer shared responsibility payment because of transition relief, has to comply with the information reporting requirements for 2015. Such ALEs will use the reporting forms to communicate to the IRS that they are eligible for transition relief under the employer shared responsibility provisions.

ALEs must furnish –

2015 Form 1095-C to each of their full-time employees by February 1, 2016 (since January 31, 2016 is a Sunday), and
2015 Form 1094-C and Form 1095-C to the IRS by February 29, 2016 (since February 28, 2016 is a Sunday) if filing on paper, or March 31, 2016, if filing electronically.

Small Employers with self-insured plans must furnish –

2015 Form 1095-B to each of their covered employees by February 1, 2016 (since January 31, 2016 is a Sunday), and
2015 Form 1094-B and Form 1095-B, to the IRS by February 29, 2016 (since February 28, 2016 is a Sunday) if filing on paper, or March 31, 2016, if filing electronically.

ALE

Not ALE

Insurer

Fully-Insured Plan

Form 1094-CForm 1095-C (Part I & II)

N/A

Form 1094-B

Form 1095-B

Self-Insured Plan

Form 1094-C

Form 1095-C (All Parts)

Form 1094-B

Form 1095-B

N/A

This information will assist the IRS in determining –

Compliance with the Employer Mandate (by the ALE), and
Eligibility of employees for the Premium Tax Credit.

If you have engaged an outside payroll service for your payroll processing, the payroll service should be handling the filing requirements, if any, for you. We would recommend calling them for assurance. For clients who are using QuickBooks to process their payroll, Intuit Payroll Services has announced that they will not support the ACA filing requirements at this time.

Please be aware that it will take time to gather the necessary information needed to meet the deadlines for these filing requirements. If you think that you may have a filing requirement for 2015, or if you will need our help to complete these forms, please contact us as soon as possible.

Please note that the purpose of this write-up is to give you a brief overview of the upcoming new reporting requirements and does not cover all the details.