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Employer Mandate


As we become closer to 2016, all “Large Employers”—those with 100 or more full-time and FTE employees—must also be prepared to comply with the Affordable Care Act Employer Mandate requirement. Specifically, the Employer Mandate requires large employers to report the coverage offered to each eligible employee during 2015 using Forms 1094-C and 1095-C. For 2016, large employers with 50 or more full-time and FTE employees are required to report coverage offered to eligible employees during 2016.

Forms 1094-C and 1095-C are filed by employers that are required to offer health insurance coverage to their employees under the Affordable Care Act. The main difference is that Form 1095-C provides information about health insurance and is sent to both employees and the IRS, while Form 1094-C acts as a cover sheet about the 1095-C and is sent only to the IRS.

What is Form 1095-C?
Form 1095-C is a new form created under the Employer Mandate. Form 1095-C is used to collect information about applicable large employers and the group health coverage, if any, they offer to their full-time employees. Employers will provide Form 1095-C (employee statement) to employees and file copies, along with Form 1094-C (transmittal form), to the IRS. Form 1095-C is comprised of three parts:

• Part I: Identifying information about the employee and the employer.
• Part II: Information about the employer’s offer of group health coverage.
• Part III: Information about the employer’s self-funded health coverage (if any), including names and Social Security numbers of the employee and his or her covered dependents.

When does the new reporting requirement start?
The requirement first applies for calendar year 2015 with reports due in early 2016:

• 2015 Form 1095-C (employee statement): Due January 31, 2016.
• 2015 Form 1094-C (transmittal form with copies of Forms 1095-C): Due February 29, 2016 (or March 31, 2016, if filing electronically).

The due dates are the same as the due dates for Form W-2 for the same calendar year. If the due date falls on a weekend or legal holiday, the employer may file by the next business day.

 

If the employer is part of a controlled group, which entity has to provide Form 1095-C?
Entities that belong to the same controlled group, e.g., parent/subsidiaries companies or sister companies under common control, are counted together and their combined employee size determines if they are an applicable large employer. If so, each entity in the controlled group is deemed an applicable large employer that must complete the reporting requirements. Each of the entities will report under its Employer Identification Number (EIN).

What is Form 1094-C?
Employers will file copies of Forms 1095-C with transmittal Form 1094-C to the IRS. The employer will indicate on Form 1094-C if it is eligible for alternative (simplified) reporting. Employers also will use this form to certify that the employer is eligible for transition relief under the ACA “pay or play” rules, if applicable.

 

In the case of an Aggregated ALE Group, each separate employer (referred to in these instructions as an ALE Member or employer) must file its own Authoritative Transmittal. Although an employer may file multiple Forms 1094-C, one “Authoritative Transmittal” Form 1094-C, identified on line 19, Part I as the Authoritative Transmittal, must be filed for each employer reporting aggregate employer-level data for all full-time employees of the employer.

Forms and instructional materials include:

 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.
Instructions for Forms 1094-C and 1095-C.
• A short brochure designed by the IRS to help employers under the reporting requirements and the type of information needed to complete the forms.

Image of a piece of paper with wording on it

Employer Reporting


As we become closer to 2016, all “Large Employers”—those with 100 or more full-time and FTE employees—must also be prepared to comply with ACA’s Reporting Requirement. Specifically, the ACA requires large employers to report the coverage offered to each eligible employee during 2015 using Forms 1094-C and 1095-C. For 2016, large employers with 50 or more full-time and FTE employees are required to report coverage offered to eligible employees during 2016.

Forms 1094-C and 1095-C are filed by employers that are required to offer health insurance coverage to their employees under the Affordable Care Act. The main difference is that Form 1095-C provides information about health insurance and is sent to both employees and the IRS, while Form 1094-C acts as a cover sheet about the 1095-C and is sent only to the IRS.

What is Form 1095-C?
Form 1095-C is a new form designed by the IRS to collect information about applicable large employers and the group health coverage, if any, they offer to their full-time employees. Employers will provide Form 1095-C (employee statement) to employees and file copies, along with Form 1094-C (transmittal form), to the IRS. Form 1095-C is comprised of three parts:

• Part I: Identifying information about the employee and the employer.
• Part II: Information about the employer’s offer of group health coverage.
• Part III: Information about the employer’s self-funded health coverage (if any), including names and Social Security numbers of the employee and his or her covered dependents.

 

When does the new reporting requirement start?
The requirement first applies for calendar year 2015 with reports due in early 2016:

• 2015 Form 1095-C (employee statement): Due January 31, 2016.
• 2015 Form 1094-C (transmittal form with copies of Forms 1095-C): Due February 29, 2016 (or March 31, 2016, if filing electronically).

The due dates are the same as the due dates for Form W-2 for the same calendar year. If the due date falls on a weekend or legal holiday, the employer may file by the next business day.

If the employer is part of a controlled group, which entity has to provide Form 1095-C?
Entities that belong to the same controlled group, e.g., parent/subsidiaries companies or sister companies under common control, are counted together and their combined employee size determines if they are an applicable large employer. If so, each entity in the controlled group is deemed an applicable large employer that must complete the reporting requirements. Each of the entities will report under its Employer Identification Number (EIN).

What is Form 1094-C?
Employers will file copies of Forms 1095-C with transmittal Form 1094-C to the IRS. The employer will indicate on Form 1094-C if it is eligible for alternative (simplified) reporting. Employers also will use this form to certify that the employer is eligible for transition relief under the ACA “pay or play” rules, if applicable.

 

In the case of an Aggregated ALE Group, each separate employer (referred to in these instructions as an ALE Member or employer) must file its own Authoritative Transmittal. Although an employer may file multiple Forms 1094-C, one “Authoritative Transmittal” Form 1094-C, identified on line 19, Part I as the Authoritative Transmittal, must be filed for each employer reporting aggregate employer-level data for all full-time employees of the employer.

Forms and instructional materials include:

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.
Instructions for Forms 1094-C and 1095-C.
• A short brochure designed by the IRS to help employers under the reporting requirements and the type of information needed to complete the forms.