We are less than 30 days away from the first deadlines for filing Affordable Care Act (ACA) information for the 2017 tax year. How time flies!
Here is who must file, when they must file and some helpful resources.
Who Must File
Organizations (including certain of their related entities) with 50 or more full-time or full-time equivalent employees, referred to as Applicable Large Employers (ALEs), are required to make annual information filings with the IRS under sections 4980H and 6056 of the Internal Revenue Code.
Under section 4980H, ALEs are required to offer health coverage to their full-time employees (and their dependents) or potentially be assessed an employer shared responsibility payment (ESRP) if at least one full-time employee receives a premium tax credit for obtaining healthcare coverage through the Healthcare Marketplace, which is Healthcare.gov and other state-operated exchanges.
Under Section 6056, ALES are required to file information returns with the IRS to identify whether they offered health coverage to their full-time employees (and their dependents) and information about the offer of coverage. This is done using IRS forms 1094-C and 1095-C. ALEs must also provide a copy of the information to their full time employees using form 1095-C.
Form 1094-C summarizes the ALE’s 1095-C information returns. It includes:
- ALE’s address, phone number, employer identification number
- Numbers of full-time and total employees
- Contact person
- How many 1095-C forms are being submitted
Form 1095-C is seeking confirmation as to whether health coverage was offered to 95% of the ALE’s full-time employees and their dependents. They are provided to the IRS and copies are also provided to each full-time employee. The form includes:
- Healthcare coverage offered to the employee
- Lowest-cost premium available to the employee
- Months of the year when the coverage was available
ALEs that are self-insured may use forms 1094-B and 1095-B to provide information about other covered individuals to the IRS.
Upcoming Deadlines
| February 28, 2018 | Deadline to file 1094-C/1095-C schedules if paper filing |
| March 2, 2018 | Deadline to furnish 1095-C schedules to employees (extended from January 31) |
| April 2, 2018 | Deadline to file 1094-C/1095-C schedules if electronic filing |
| July 31, 2018 | Form 720 (PCORI) due from self-insured plans (includes self-insured employers) |
Resources
Here are links to the final forms and instructions on the IRS website:
- Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.
- Form 1094-C, Transmittal form accompanying Form 1095-C information returns.
- Instructions for Forms 1094-C and 1095-C.
- Form 1095-B, Health Coverage.
- Form 1094-B, Transmittal form accompanying Form 1095-B information returns.
- Instructions for Forms 1094-B and 1095-B.
Get access to the ACA Resource Center by clicking here.
We’re committed to helping companies reduce risk, avoid penalties, and achieve 100% ACA compliance. For questions about the ACA contact us here.
