Annual Affordable Care Act Reporting Requirements Beginning January 2

Additional Annual Affordable Care Act Reporting Requirements Beginning January 2016

Under the Affordable Care Act, new information reporting requirements will be implemented beginning with the 2015 calendar year.  The reporting requirements are intended to promote transparency with respect to health plan coverage and costs.  Individuals and the Internal Revenue Service will use the information reported for the purposes of verifying an individual’s eligibility for the premiums tax credit and to show compliance with the health care mandates.

Who must file?
Every person that provides minimum essential coverage to an individual during a calendar year must file a separate statement for each individual and a single transmittal form.  Minimum essential coverage includes insured and self-insured plans, COBRA coverage, retiree coverage, qualified health plans offered by the Health Insurance Exchange (Marketplace), Medicare Part A, Medicaid, the Children’s Health Insurance Program (CHIP) and TRICARE coverage.  Minimum essential coverage does not include supplemental coverage such as Health Reimbursement Accounts (HRAs), Health Savings Accounts (HSAs), coverage at on-site medical clinics or Medicare Part B.

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What to file

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  • Applicable large employers sponsoring self-insured plans: File Form 1094-C and 1095-C (Parts I, II, and II)
  • Applicable large employers sponsoring insured plans: File Form 1094-C and 1095-C (Parts I and II only)
  • Non-Applicable large employers sponsoring self-insured plans: Form 1094-B  and 1095-B
  • Non-Applicable large employers sponsoring insured plans are not required to report under the new code sections.

An applicable large employer is an employer that employed, on average, at least 50 full-time employees during the prior year.  This includes full-time equivalent employees.

When to File the Forms
IRS Returns:

  • Due annual on or before February 28th (March 31st, if filed electronically)
  • For 2015, due date is February 29, 2016 (March 31st, if filed electronically)
  • Electronic filing is REQUIRED if filing 250 or more returns

Individual Statements:

  • Due annually by January 31st
  • For 2015, due date is February 1, 2016
  • May be furnished electronically if requirements are met.

The IRS will assess penalties for failure to timely file, failure to include all required information, and for including incorrect information.  For incorrect and/or incomplete information reported in 2016 related to 2015 coverage, penalties will not be imposed on reporting entities that can show good faith efforts to comply.

If you have any questions regarding the new filing requirements, please feel free to contact Michele D. Burkins at