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Employer Reporting for ACAIRS Forms

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Forms Supporting the Affordable Care Act

Seven Forms• Employer Forms:

• REQUIRED for all Large Employers as Defined by the ACA (50+ FTE)’s

• Report by EIN • The EIN that issues the W2 issues the 1095

• First required filing: January 2016 for the 2015 calendar year• 1094-C (Employer Mandate)• 1095-C (Individual & Employer Mandate)

• Other Forms:• Insurance Company and Self-Insured Small Employers

• 1094-B • 1095-B

• Exchange/Individual Coverage • Individual Tax Forms

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Employer Mandate Reporting: 1094-C

1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns -

• General information, including: • Name, EIN, address• Total Number of Forms• Controlled group information

• Certification of simplified reporting methods being used:• Qualifying Offer Method• Qualifying Offer Method Transition Relief• Section 4980H Transition Relief• 98% Offer Method

• Multiple 1094-C forms may be filed, with a final, authoritative return for the entire group. • For example, if there are multiple divisions filing separately.

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1094-C Simplified Reporting: More than one box may be checked:• Qualifying Offer Method: you will be providing simplified reporting

for a portion of employees for whom affordable (FPL), minimum value coverage was offered for all months in the calendar year the employee was full time.

• Qualifying Offer Method Transition Relief: you are certifying that for one or more months in 2015, you offered affordable (FPL), minimum value coverage to at least 95% of your full time employees.

• Section 4980H Transition Relief: this is available for employers with fewer than 100 FTE’s, non-calendar year plans (must pass the significant percentage tests), those covering less than 95%, but more than 70% of their full-time workforce, etc.

• 98% Offer Method: you are certifying that you offered, for all months in the calendar year, affordable, minimum value coverage to at least 98% of your employees for whom you are filing a 1095-C and their dependents.

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1094-C Simplified Reporting:

What do you gain with simplified reporting?

• Reporting for each month is not required• No requirement to report contributions on 1095-C• Under 98% Offer Method – no need to report full time employee

count.

It is possible to have simplified reporting for some employees, but not all, and to have different simplified reporting methods for different groups of employees.

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1094-C Part III:

1. Check “Yes” only if coverage was offered to 70% (2015) or 95% (2016 and beyond) of full time employees and dependents.

2. When determining, do not include full time employees in a limited non-assessment period.

3. You may only check the “All 12 Months Box,” if you meet the 70%/95% threshold for the entire year.

4. Non-calendar year plans that qualify for transitional relief will check “NO” for months coverage wasn’t offered, but indicate in column E that they were transition relief eligible.

5. Employer groups under 100 lives that qualify for transitional relief will check “NO,” but indicate in column E that they were transition relief eligible.

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1094-C Part III:

1. Not required if using 98% Offer Method2. Do not count employees in a limited non-

assessment period.

1. All full time + non-full time employees2. If the employee count remains unchanged for

the entire year, you may use the “All 12 Months” box.

3. Counts must be made as of 1) the first or last day of the calendar month or 2) the first or last day of the first payroll period of the month and be consistent.

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1094-C Part III:

1. Employers with fewer than 100 FTE’s enter “A”

2. Employers with non-calendar year plans enter “B”

All transition relief must be qualified through various tests/measures.

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1094-C Part III:

Limited Non-Assessment Periods:

1. First year as an ALE: January – March for individuals not offered coverage in the prior year.

2. Eligibility waiting periods3. Initial Measurement Period & Administrative Period4. The period following a change in status during an initial

measurement period. 5. First calendar month of employment, if a partial month.

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1094-C Part IV: Add the Business Entity Names and EIN’s of any members of the

controlled group.

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1095-C Individual & Employer Mandate:

1095-C: Employer-Provided Health Insurance Offer and Coverage:• One form per employee per employer.• Provided to individuals who were full-time employees for any month

in the calendar year. • Provided also to individuals who are not full time, but were covered

by the health plan (including non-employees)

All Health Plans: Part I: Employee and Employer InformationPart II: Employee Offer and Coverage Information

Self-Funded Health Plans Only:Part III: Covered Individual Information

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1095-C Part I:

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• All Large Employers• All Full-Time Employees• All Employees enrolled in coverage who are not full-time

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1095-C Part II:

• All Large Employers• All Full-Time Employees• All Employees enrolled in coverage who are not full-time

1. Indicate by code, whether coverage was offered during all 12 months, or if less, during which months. There are nine codes to choose from.

2. Only count months in which coverage was offered for the entire month – partial months allowed only during month of termination

3. If an offer of coverage is made under a self-funded plan to a non-full time employee (including COBRA and retirees), use Code 1G.

4. Code 1I will be used for months in which no offer of coverage was made, but the employer was under Transition Relief.

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1095-C Part II:

• All Large Employers• All Full-Time Employees• All Employees who enrolled in coverage but not full-time

1. Do not complete this line if you are using Qualifying Offer or Qualifying Offer Transitional Relief as simplified reporting methods.

2. Only complete if using codes 1B, 1C, 1D, or 1E in line 14. 3. If the cost of coverage for the lowest cost, minimum

value plan does not change during the year, use the “All 12 Months” box, otherwise report monthly.

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1095-C Part II:

• All Large Employers• All Full-Time Employees• All Employees who enrolled in coverage but not full-time

1. Indicator codes to provide relief in the event coverage was not offered or you are using a safe harbor for all or part of the calendar year.

2. Nine codes, include: • Transition relief• Enrolled in Coverage• Part Time Employee• Not employed during the month• Affordability Safe Harbors• Limited Non-Assessment Periods

3. Always use “2C” when the employee has enrolled in coverage.

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1095-C Part III:

• Only Self-Funded Health Plans• All Full-Time Employees enrolled in coverage• All Employees enrolled in coverage who are not full-time

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1095-C Alternative Furnishing Methods:

• 1095-C forms must be provided to the IRS• Employers eligible for simplified reporting under the Qualifying Offer

Method may use an Alternate Furnishing Method, rather than provide 1095-C to their employees a statement containing the following:

1. Employer name, address, and EIN2. Contact name and telephone number3. A statement that, for all 12 months of the calendar

year, the employee and his or her spouse and dependents, if any, received a Qualifying Offer and therefore are not eligible for a premium tax credit.

• Part III of the 1095-C still needs to be filled out for self-funded plans.

• This Alternative Furnishing Method is also available in 2015 for employers using the Qualifying Offer Method Transitional Relief.

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Other Reports:

• Insurance Company and Self-Funded Small Employer Reports: 1094 and 1095-B

• Exchange Reports: 1095-A (reports subsidy received during the tax year)

• Individual Tax Filing Reports:• 8962: Accompanies the 1040 of an individual who receives a

subsidy• 8965: Accompanies the 1040 of an individual who has an

exemption from the individual mandate.

Thank you!The information in this document should not be construed as all inclusive or constituting legal or tax advice. Consultation with your legal and/or tax professional for detailed information regarding your

concern is advised. This document contains information that may continue to be updated and or changed based on new Health Care Reform regulations or guidance. Any dissemination, copying, or

disclosure of this communication is prohibited without express written authorization.

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