Even though the effective date for the employer mandate to offer health coverage to all employees or pay a penalty has been delayed, employers still must pay attention to reporting requirements under health care reform. The Affordable Care Act requires employers to report to the government statistics on their health insurance offerings. Last week, the government released guidance that is intended to ease employers’ reporting obligations.
The employer mandate requires employers with 50 or more full-time employees to provide affordable health coverage or pay a fine per worker after the first 30 employees. Employers subject to the mandate must file a return with the IRS indicating, among other things, the number of full time employees and certain information about health coverage offered to those employees. The new proposed guidance provide that employers will report the following information:
- The name, address and EIN of the employer; the name and telephone number of a contact person; and the calendar year of the information;
- Certification as to whether the employer offered to full time employees and their dependents the opportunity to enroll in minimum essential coverage;
- The number of full time employees for each month during the calendar year;
- For each full time employee, the months during the calendar year for which coverage under the plan was available;
- For each full time employee, the employee’s share of the lowest cost monthly premium for coverage offered to the employee by calendar month;
- The name, address and TIN for each full time employee during the calendar year and the months if any during which the employee was covered under the plan.
The proposed regulations ask employers to provide comments on how reporting can be streamlined. The proposed regulations indicate that some previously required information will not be required to be reported, as the government has this information from other means. This includes
- Length of any waiting period;
- Employer’s share of the total allowed costs of benefits;
- Monthly premium for lowest cost option in each of the enrollment categories; and
- Months dependents were covered under the plan.
While reporting will not be required in 2014, employers should start thinking about how they will collect the required data and have it available to provide to the IRS when reporting is required with respect to coverage provided in 2015.
