Employers: First Healthcare Reform Reporting Deadline is March 31

Authored by Dannae L. Delano

Mar 29, 2016

The deadline for many employers and self-funded plan sponsors to provide individual healthcare statements to their full-time employees and participants is this Thursday. This is the first deadline for this type of reporting under the Affordable Care Act.

Applicable Large Employers (50 or more full-time and full-time equivalent employees in 2014) and Self-Funded Plan Sponsors (employers who sponsor self-funded group health plans) must provide plan participants with Form 1095-Cs or 1095-Bs on or before March 31, 2016 to avoid significant penalties.

If you are an Applicable Large Employer responsible for filing Form 1095-C and need help coding it correctly—particularly lines 14, 15, and 16—contact us for further information regarding:

  • Retirees and other non-employees who are on a company health plan;
  • Former employees who elect COBRA continuation coverage;
  • Union employees in a multiemployer plan;
  • Employees who were offered minimum essential coverage but declined such offer due to other coverage;
  • Non-calendar year plans entitled to transition relief for 2015;
  • How to utilize affordability safe harbors;
  • How to properly utilize a Qualifying Offer (Code 1A);
  • Situations in which two employees share family coverage (for example, two spouses who both work for you, or a parent and child);
  • Other Form 1095-C coding questions.

If you are a Self-Funded Plan Sponsor and completing Part III of the Form 1095-C or Form 1095-B, you should check each month a participant has even one day of coverage for that month. This contrasts to completion of lines 14 and 16, which are coded only if true for every day of the calendar month indicated.

Other pending deadlines will include filing applicable forms with the IRS on or before May 31, 2016 (paper) or June 30, 2016 (electronic). If you are required to file 250 or more forms, you are required to file electronically.

The IRS has stated that, for the 2015 reporting year, it will not impose penalties on filers who report incorrect or incomplete information where there is a good faith effort to comply with the law.  However, you cannot take advantage of the more lenient good faith standard if you do not file the returns. Regardless, if you miss the deadline, you should file as soon as possible to mitigate the penalties and interest that the IRS can assess against you.

If you have any questions about ACA compliance, ACA reporting or any other employee benefits matter, please do not hesitate to contact Dannae Delano or Jamie Westbrook.

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