IRS gives employers some key points on reporting requirements

The IRS has published what it considers to be key points for employers to keep in mind about upcoming reporting requirements. Under the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148), employers with 50 or more full-time employees in the preceding year are considered to be applicable large employers, or ALEs, and they must report certain health coverage information on returns filed with the IRS and included in statements furnished to full-time employees.

If you are an ALE, you must include information regarding whether or not you offered health coverage to each of your full-time employees. This information is being sought by the IRS to aid it in determining if you owe an employer shared responsibility payment, and whether or not any of your employees are eligible for a premium tax credit.

The IRS states that the following are key points it wants ALEs to keep in mind about the ACA’s information reporting requirements:

• If you are an ALE, you are required to report certain information to the IRS, as well as to all of your full-time employees, regardless of whether you offer health insurance coverage.

• These ALE reporting requirements are new. Your first information reporting returns are due in 2016 for the year 2015.

• There are new IRS forms that ALEs will use to complete this reporting – Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. Form 1094-C is used to report to the IRS summary information and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each full-time employee, and is the form that is furnished to full-time employees.

• If you are an ALE, you are required to furnish each full-time employee with a statement, Form 1095-C, by Jan. 31 of the calendar year following the calendar year to which the information relates. Because Jan. 31, 2016 is a Sunday, the Jan. 31 due date will shift to Feb. 1, 2016. You will meet the requirement if the form is properly addressed and mailed on or before the due date.

• If you are an ALE, you must file the information returns Forms 1094-C and 1095-C with the IRS no later than Feb. 28 – or March 31 if filed electronically – of the year immediately following the calendar year to which the return relates. Because the 2016 deadline falls on a Sunday, the Feb. 28 due date will shift to Feb. 29, 2016.

• Even if you’re an ALE that is not liable for an employer shared responsibility payment because of transition relief, you still have to comply with the information reporting requirements for 2015. You use the reporting forms to communicate to the IRS that you are eligible for transition relief under the employer shared responsibility provisions.

• If you’re an ALE that sponsors a self-insured group health plan for your employees, you also must report information about employees and their dependents who enroll in the coverage, whether or not the employee is a full-time employee.

Filing requirements. The IRS also reminds ALEs that if they need to file at least 250 information returns during the calendar year, Form 1095-C and Form 1094-C must be filed electronically.
Each of your full-time employees must be provided with a copy of the Form 1095-C that you file with the IRS. You may provide statements to employees either on paper by mail or hand delivery, unless the recipient affirmatively consents to receive the statement in an electronic format.

SOURCE: IRS Health Care Tax Tip 2015-62, October 6, 2015

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