Employee health insurance: Mandated ACA reporting for 2016

Posted on: October 28th, 2015

With the arrival of 2016 there will be yet another onus on employers of more than 50 people.

Under the Affordable Care Act (ACA), IRS Section 6055/6054, employers are mandated to file forms 1094C and 1095C (or 1094B/1095B for small, self-insured employers) to report the proper offering of 2015 healthcare coverage to each employee.

The purpose of this new reporting is to assist the federal government in enforcing compliance with both the employer and individuals on the mandates under the ACA. In other words, it’s making sure individuals have coverage or that those who are receiving the government subsidy/payments are eligible for them. It’s also verifying that employers are offering ACA coverage and therefore not subject to the employer penalty.

Employers must provide form 1095C to each employee to show the coverage that was in force for them, or offered to them, for each of the 12 months in 2015, to show they are in compliance with the individual mandate. This form must be provided to each employee along with his or her W-2 for 2015 — by January 31, 2016 (and that date or the closest to it after a weekend in subsequent years).

Employers use form 1094C to report to the IRS that they offered ACA coverage for 2015 and which employees were offered the coverage. This form must be submitted by February 28 most years, but February 29, 2016, since it is a leap year. If this report is filed electronically, the due date is March 31, 2016.

This is just another hurdle in the Affordable Care Act, which is anything but affordable, says Cindi Johnston, director of group benefits for Seaside Insurance, Inc., in Orlando, Fla. She explains that many employers now have to pay for additional services to generate these reports to be processed on top of the cost of offering the health coverage.

The information that must be reported to the IRS is:

  1. The employer’s name, address and EIN.
  2. The name and telephone number of the contact person at the place of employment.
  3. The calendar year for which the information is reported.
  4. The number of full-time equivalent employees (FTEs) for each month during the calendar year.
  5. The months during the calendar year that minimal essential coverage (MEC) was available.
  6. Certification as to whether the employer offered its FTEs and their dependents the opportunity to enroll in MEC, by calendar month.
  7. Each FTE’s share of the MEC’s self-only premium, by calendar month.
  8. Name, address and TIN (or DOB) of each FTE employed during the calendar year.
  9. Months, if any, during which each FTE was covered under the plan.


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