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ALERT: ACA Reporting Deadline of January 2016 Requires Information-Gathering Now for Eligible Employers

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August 25, 2015

Mandatory employer reporting for the Affordable Care Act begins in January 2016 for entities which are “applicable large employers.” If your organization falls into that category and you have not already begun gathering the long list of IRS-required information, you should begin immediately. Please note: regardless of the number of employees, any organization that has a self-funded health care plan is required to complete ACA reporting.

Applicable large employers who do not report the required information may be assessed significant penalties for noncompliance. Penalties were sharply increased in July of 2015 and are based on each failure to file an informational or payee return. If the entity fails to file BOTH an informational return and a payee statement, penalties are $500 per statement with a $6,000,000 cap.

Here’s what you should know about whether you will need to report and what will need to be reported.*

Are You an Applicable Large Employer?

The IRS defines an applicable large employer as any organization with at least 50 full-time or full-time equivalent employees for the previous calendar year. For help determining whether your organization qualifies and must report, visit this IRS webpage or call AGH’s organizational development professionals.

Reporting Requirements

If you determine you are an applicable large employer, you’ll need to gather and be able to report the following information for each month of the previous calendar year:

  • Who was a full-time (or full-time equivalent) employee for each month
  • Total employee counts for each month
  • Name, address and other identifying information for both the employer and each employee
  • What health care coverage was offered for each month, if any
  • The employee share of the monthly premium for lowest-cost self-only minimum value coverage
  • How many months each employee was in enrolled in your coverage
  • How many months your organization met affordability safe harbor requirements (see the IRS website for more information)
  • If you offer a self-insured plan, information about the covered individuals in each plan

The IRS forms required for ACA reporting, 1094-C and 1095-C, can be found on the IRS website. In addition, self-funded plan sponsors who are not applicable large employers must also complete forms 1094-B and 1095-B.

As you can see from the previous list, the earlier you begin gathering the required information, the better. If you have questions regarding ACA compliance and reporting, please contact Carrie Wiegand using the information below.

Carrie Cox, PHR, SHRM-CP

Senior Organizational Development Consultant,
Organizational Development & Family Business Services
Carrie has experience in a variety of human resource functions, including labor laws, compensation structures, employee classification, benefits administration, performance management, and human resource best practices. She has served clients in a number of industries including manufacturing, construction, banking, and not-for-profits. Carrie is a member of the national and local chapters of the Society of Human Resource Professionals (SHRM) and serves on the Wichita chapter board of directors.

She is a certified practitioner for the Myers-Briggs Type Indicator® and the Hay Group’s Emotional and Social Competency Inventory. Her additional certifications include Professional in Human Resources (PHR) from the Human Resource Certification Institute and SHRM-CP designated by the Society for Human Resource Management.
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Carrie Cox, PHR, SHRM-CP
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*Known as of article’s original publication date. Refer to the IRS' ACA webpage for the most recent reporting requirements.