Kilpatrick

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Employer Reporting Requirements under the ACA

Update 11/29/2018: The IRS extended the deadline for providing the statements to employees/individuals in 2019. No extension for the IRS filing deadlines.

Applicable Large Employers and all employers who offer self-funded plans are required to provide annual statements to employees and information returns to the IRS about the health coverage they offered (or did not offer) in the prior year. The IRS uses the statements and returns to confirm compliance with the employer and individual mandates and to administer subsidies in the individual market. Small employers who did not offer any coverage or only offered fully insured coverage are not subject to the reporting requirements summarized in this article. All other employers are.

The reporting is comprised of two forms: Employee Statements (Form 1095) and an IRS Transmittal (Form 1094). Employers send statements to each employee and file the statements with the IRS in conjunction with a the summary information transmittal.

Reporting Required from Large Employers

You are an Applicable Large Employer (ALE) if you averaged at least 50 full-time employees, including equivalent employees, during the prior calendar year. See Determining if an Employer is an Applicable Large Employer. ALEs use the C-series forms to report. ALEs who offered self-funded coverage complete Part III of each listing the employee and dependents covered by the plan and the period of the coverage. ALEs filing 250+ employee statements must file electronically.

2019 Deadlines

  • Statements to Employees: Mar 4
  • Submission to the IRS: Apr 1 (if electronic) or Feb 28 (if paper)

Reporting Required from Small Employers about Self-Funded Plans

Small employers who offered self-funded coverage and are not ALEs are required to report about each employee and their dependents who were covered by a plan at any point in the year and the period of the coverage. Employers use the B-series forms.

2019 Deadlines

  • Statements to Employees: Mar 4
  • Submission to the IRS: Apr 1 (if electronic) or Feb 28 (if paper)

Additional Resources

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