Last week, the IRS released new Frequently Asked Questions and Answers addressing health care reform reporting requirements. The Affordable Care Act requires applicable large employers (those with 50 or more full-time employees) (called an ALE) to file information returns with the IRS and provide statements to their full-time employees about the offer of health coverage. An ALE may consist of a single employer member or a group of related employers. The reporting requirements apply to each separate member of the group. ALE members that sponsor self-insured group health plans also report information about the health coverage provided by filing information to the IRS and providing coverage information to employees.
The FAQs provide some new guidance:
- An ALE member that has a workforce comprised entirely of part-time employees who were not full-time in any month of the year does not have to file Form 1095-C
- An employer that is not a large employer is not required to File Form 1094-C.
- An ALE member that sponsors a self-funded health plan is required to File Form 1094-C and Form 1095-C even if the ALE member has no full-time employees.
- An ALE member that sponsors a self-funded health plan in which a non-employee is covered (such as an ex-spouse on COBRA coverage) may file Forms 1094-B and 1095-B for the individual.
- An ALE member that sponsors a self-insured health plan will report to their employees who are covered by the plan on Part II of form 1095-C. Employees with insured plans will receive information about coverage from the Insurer on Form 1095-B.
- An employer should enter a code indicating no offer of coverage was made for employees in the month they were hired unless the employee was covered on every single day of the calendar month.
- An employer should report that no coverage was made the entire month during which an employee is terminated, unless the employee was covered every day of the month.
Employers should be actively counting employee hours and gearing up for the new health care reform reporting requirements. For information about how BAS’ ACA data collection and reporting tool can work for you, contact solutions@BASusa.com.