Take Action on the Critical Provisions of Health Care Reform

Posted on 01.22.15

Take Action on the Critical Provisions of Health Care Reform

By Mark D. Balderson | Tax Senior Associate
Beginning with the 2015 tax year, employers determined to be an Applicable Large Employer (ALE), meaning you have 50 or more full time employees, may be subject to the Employer Mandate provisions of the Affordable Care Act (ACA).  Employers with less than 50 full time employees are not subject to these particular provisions of the ACA.  These provisions bring additional responsibility and requirements to employers to file additional payroll forms to document their compliance with the employer shared responsibility provisions under IRC Section 4980H.  The new forms, Form 1094-C and Form 1095-C, are not required to be filed by any employer for 2014.  The first filing requirement will be in 2016 for the 2015 calendar year.  However, in preparation for the first required filing of these forms, employers may, if they wish, voluntarily file in 2015 for 2014.

Employers with 50 or more full-time employees (including full-time equivalent employees) use Forms 1094-C and 1095-C to report the information required under IRC Sections 6055 and 6056 related to the health insurance coverage it offers and enrollment in such coverage for their employees.  Form 1094-C must be used to report to the IRS summary information for each employer while Form 1095-C is used to report information about each employee (including determining eligibility of employees for premium tax credits).  In addition, both Forms 1094-C and 1095-C will be used in determining whether an employer owes payments under the employer shared responsibility provisions under IRC Section 4980H.

  • You must file Forms 1094-C and 1095-C by February 29, 2016, for calendar year 2015 (or March 31, 2016, if filing electronically).  Forms 1094-C and 1095-C are subject to the requirements to file returns electronically.

  • Form 1095-C must be provided to the individual employees no later than January 31 of the year following the year which the returns relate.  The first Forms 1095-C is due to individual employees by February 1, 2016.

Please contact your payroll service provider as soon as possible to ensure proper compliance and documentation is already underway for proper filing of these forms for calendar year 2015.  Should you have any questions or concerns in determining if you are an Applicable Large Employer (ALE) or determining if any additional benefits coverage needs to be applied to your current coverage offerings, please don’t hesitate to contact your Keiter advisor or information@keitercpa.com | Phone: 804.747.0000

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Mark BaldersonMark is a Tax Senior Associate at Keiter.  Mark applies his tax experience to provide the insights needed to help his clients manage and grow their businesses. Read more of Mark's tax insights on our blog.