By Danielle Capilla
Chief Com­pli­ance Offi­cer at Unit­ed Ben­e­fit Advisors

FinancialPaperworkUnder the Patient Pro­tec­tion and Afford­able Care Act (ACA), indi­vid­u­als are required to have health insur­ance while applic­a­ble large employ­ers (ALEs) are required to offer health ben­e­fits to their full-time employ­ees. In order for the Inter­nal Rev­enue Ser­vice (IRS) to ver­i­fy that (1) indi­vid­u­als have the required min­i­mum essen­tial cov­er­age, (2) indi­vid­u­als who request pre­mi­um tax cred­its are enti­tled to them, and (3) ALEs are meet­ing their shared respon­si­bil­i­ty (play or pay) oblig­a­tions, employ­ers with 50 or more full-time or full-time equiv­a­lent employ­ees and insur­ers will be required to report on the health cov­er­age they offer. (If ALEs are not offer­ing cov­er­age, they will have to report on that, too).

Report­ing will first be due ear­ly in 2016, based on cov­er­age in 2015. All report­ing will be for the cal­en­dar year, even for non-cal­en­dar year plans. Mid-size employ­ers (those with 50 to 99 employ­ees) will report in 2016, despite being in a peri­od of tran­si­tion relief in regard to hav­ing to offer cov­er­age. The report­ing require­ments are in Sec­tions 6055 and 6056 of the ACA. Sec­tions 6055 and 6056 report­ing is done on IRS Forms 1094‑C, 1095‑C, 1094‑B, and 1095‑B.

For cal­en­dar year 2015, the required forms must be filed by Feb­ru­ary 29, 2016, or March 31, 2016, if fil­ing elec­tron­i­cal­ly. Employ­ers with 250 or more 1095 Forms must file elec­tron­i­cal­ly with the “Afford­able Care Act Infor­ma­tion Returns” or AIR. The IRS is encour­ag­ing all enti­ties to file elec­tron­i­cal­ly. Employ­ers uti­liz­ing a ven­dor ser­vice should con­firm that the ser­vice they are using can han­dle the act of report­ing, elec­tron­ic or oth­er­wise. Employ­ers using a ven­dor should con­firm that their cho­sen ven­dor is set up to file the returns for them, and have or will have suc­cess­ful­ly com­plet­ed the test­ing phase. Employ­ers who wish to use a ven­dor instead of fil­ing them­selves should be aware that many of the report­ing ven­dors have a capped amount of clients they can assist.

Employ­ers who are doing their own elec­tron­ic fil­ing should ensure they are ready to use the AIR sys­tem. Being ready to use the sys­tem is a time-con­sum­ing process; ample time should be giv­en to ensure an employ­er is up and running.

For detailed infor­ma­tion on the steps employ­ers should fol­low to use AIR, down­load UBA’s ACA Advi­sor, “Afford­able Care Act Infor­ma­tion Returns”

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