New Affordable Care Act Forms and Business Reporting Requirements for 2015

New Affordable Care Act Forms and Business Reporting Requirements for 2015

The Affordable Care Act requires that large employers, namely those with 50 or more equivalent (taking into account the hours work by part-time employees) full-time employees, take some new actions. These employees are required to complete IRS informational returns for full-time employees regarding the healthcare coverage offered by the employer.

In 2014, information reporting was voluntary. For 2015, all large employers are required to report information regarding health coverage for the first time starting in early 2016.

The preparation that is required to issue Form 1095-C and report to the IRS, means that you'll have to:

  • Figure out if your organization qualifies as a large employer.
  • Review the type of health insurance coverage that you offered to the full-time employees and their dependents, if you did offer coverage.
  • Figure out who your full-time employees are for every month and track their health coverage information for 2015 to help with completing the new IRS informational forms.

Reporting for applicable large employers

Is your business an applicable large employer?

Your business qualifies as an applicable large employer if your organization, or other entities that must be combined with your business (for example, other members of an aggregated group) employed at least 50 full-time equivalent employees, on business days for the preceding calendar year.

There is a special rule that applies for 2015 to help determine if you qualify as an applicable large employer. Under this rule, you are allowed to use any consecutive six-month period for the year 2014, rather than look at all 12 months of 2014.

Reporting requirements are applicable starting in 2015

Applicable large employers are required to meet certain reporting requirements for full-time employees. In 2015, all applicable large employers are required to meet these reporting requirements, even for those employers that meet the special rules that allow for transition relief in 2015 from the employer shared responsibility payments.

There are some reporting requirements that are also applicable to employers that offer self-insured coverage, even if this employer is not considered as an applicable large employer.

Which employees are counted when determining if you are an applicable large employer

Employers can average the number of employees at the organization using the months in the year to determine if the employer will be considered as an applicable large employer for the following year. To figure out if your organization is considered as an applicable large employer for that year, you should add up your business's full-time employees, full-time equivalent employees, and if your organization is a member of a combined group, you must also include the full-time employees and full-time equivalent employees for all members of the group for each month of the previous year and then take the average of these numbers for that year.

In general:

A full-time employee is one that maintains employment on average, per month, for 30 hours or more of service per week (or at least 130 hours of service in a calendar month).

A full-time equivalent employee is a combination of employees, each of whom is not a full-time employee when considered individually (because the individual provides less than 30 hours of service each week), but who, when combined, are equivalent to a full-time employee.

An aggregated group is commonly owned, affiliated or related employers, which are required to combine their employees to figure out the size of their workforce.

There are other rules that are used to determine full-time employee status, including those that define what counts as service hours. For additional information about these rules, you should review the employer shared responsibility final regulations and the frequently asked questions and answers available at

Preparing to complete the new IRS forms for 2015 in 2016

Form 1095-C - Employer Provided Health Insurance Offer and Coverage

  • Issue the form to full-time employees for use when filing their tax returns.
  • File as an information return with the IRS.
  • Reports information about health insurance coverage offered and any employer safe harbors or other relief available, or reports that no coverage offer was made.
  • Reports information about enrollment from employer s who provide self-insured plans and information about employees and individuals who participated in minimum essential coverage.
  • Helps the IRS figure out if your business is required to make an employer shared responsibility payment to the IRS.
  • Helps the IRS figure out whether your full-time employees and their dependents are eligible to receive the premium tax credit.

Here's what information you need for Form 1095-C

  • The list of individuals that are full-time employees for each month.
  • Identity information for employer and employee such as name and address.
  • Information on the health coverage provided for each month, if any.
  • The employees share of the monthly premium for lowest -cost self-only minimum value coverage.
  • The months that the employee was enrolled in your coverage.
  • The months that the employer was eligible for an affordability safe harbor with respect to an employee and if other relief applies for an employee for specific a month.
  • If the employer provides a self-insured plan, the details about the individuals enrolled in the plan, by month.

Form 1094-C - Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns

  • File with the IRS as a transmittal document for Forms 1095-C, Employer Provided Health Insurance Offer and Coverage.
  • Provides the IRS with a summary of aggregate employer-level information. Helps the IRS decide if an employer is required to make an employer shared responsibility payment and the estimated payment amount.

What you'll need for Form 1094-C

  • Identifying information for your organization.
  • The details for 2015 about whether you offered coverage to 70% of your full-time employees and their dependents. (After the 2015 calendar year, this threshold changes to 95%.)
  • For the authoritative transmittal

○ Total number of Forms 1095-C you issued to employees.

○ Information about members of the aggregated applicable large employer group, if any.

○ Full-time employee counts by month.

○ Total employee counts by month.

○ Whether you meet the requirements for certain transition relief. 

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