New information-reporting requirements for employers under the Affordable Care Act.

AuthorSmerud, Jenny

The deadline is approaching for employers with 50 or more full-time employees or full-time equivalents (FTEs) to file new information returns required under Secs. 6055 and 6056. The reporting requirements help administer the employer shared-responsibility mandate and the individual mandate added as a part of the Patient Protection and Affordable Care Act, P.L. 111-148. Below is a summary of what so-called applicable large employers (ALEs) need to know about the reporting requirements.

Most employers affected by the new regulations will be subject to the reporting requirements of Sec. 6056. The information reported by employers to satisfy the requirements of Sec. 6056 allows the IRS to identify employers that do not offer minimum essential coverage to their full-time employees and, if at least one such employee qualifies for a premium tax credit with respect to a qualified health plan, assess the applicable penalty to the ALE of $2,000 per year per full-time employee (or one-twelfth that amount for any month). Because employers that do offer coverage must also report specifics as to offers of coverage and cost to individuals by month, individual employees and the IRS can calculate the affordability of the coverage to the household and determine eligibility for premium credits. If an employee applies for insurance through a health care exchange and receives a premium tax credit because his or her employer's offer of coverage was not affordable or did not provide minimum value, the IRS may assess the employer for the higher $3,000 annual penalty (or one-twelfth for any month) with respect to each such fulltime employee.

To comply with Sec. 6056, an ALE must file Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, for each full-time employee and the related Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, with the IRS on or before Feb. 29, 2016 (March 31, 2016, if filed electronically), for the 2015 calendar year. The employer must furnish employee statements to employees on or before Feb. 1,2016 (since Jan. 31, 2016, is a Sunday). Employers that do not self-insure for their health coverage will complete only Part I and Part II of Form 1095-C.

An ALE must gather a significant amount of information to complete Form 1095-C, including:

* Name, address, employer identification number (EIN), and contact information for the ALE;

* Name, address, and Social Security number (SSN) for...

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