To be fully compliant employers face 8 key requirements.

  1. All “applicable large employers” are subject – The trick here is properly counting part-time and variable hour employees.
  2. January 1, 2015 was the “effective date” for the new requirements. – Even if employers qualify for temporary relief they must report 2015 calendar year data to the IRS.
  3. Employers must be able to identify their “full-time employees”. – The rules include look-back and stability periods to determine whether variable hour employees need to be offered coverage.
  4. IRS Form 1095-C is used to report employee-level data to the IRS. – This reporting uses a complicated set of codes and must be provided directly to employees and filed with the IRS. The form reports on a monthly basis whether the employer offered medical coverage to the employee, whether the coverage provided minimum value and was affordable.
  5. Self-Insured Plans need to report coverage data for employees and any covered dependents. – Regardless of the number of employees employers are required to complete Part III of Form 1095-C
  6. IRS Form 1094-C is used to report employer-level data to the IRS. – 1094-C is the “transmittal letter” to the IRS with employer-level demographic data including exemptions to the employer mandate.
  7. Employers must disclose their “controlled group” on the Form 1094-C. – The names and EINs of other ALE members must be listed. (This is the first time the IRS has required this disclosure.)
  8. Employers filing 205 or more Form 1095-C must file electronically. – The IRS required filers to use its electronic submission system. The complexity of this system will make it extremely difficult for large employers to file on their own behalf.

Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.