NEED TO FILE ACA EMPLOYER FORMS? YOU HAVE MORE TIME IN 2016

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If you’ve been having a hard time figuring out how to fully comply with the new Affordable Care Act reporting requirements for employers, you’ll appreciate that the Internal Revenue Service recently decided to give employers more time to file the ACA forms this year.

The IRS said in Notice 2016-4 that copies of the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and the 2015 Form 1095-B, Health Coverage, that are due to employees in 2016 are due March 31, two months later than the original deadline of Feb. 1. The copies of these forms, and corresponding transmittal forms (Forms 1094-B and 1094-C) now are due to the IRS by May 31 if filed by paper and June 30 if filed electronically, three months later than the respective original deadlines of Feb. 29 and March 31.

The deadline extensions are only for ACA forms reporting 2015 data in 2016. Employers that had at least 50 full-time equivalent employees in 2014 are required to file the 2015 Forms 1095-C and 1094-C in 2016 and providers of minimum essential health coverage generally are required to file the 2015 Forms 1095-B and 1094-B in 2016.

Self-insured employers that in 2015 provided minimum essential coverage and that in 2014 had fewer than 50 full-time equivalent employees are required to file 2015 Forms 1095-B and 1094-B in 2016.  Self-insured employers that in 2015 provided minimum essential coverage and that in 2014 had at least 50 full-time equivalent employees may report provisions of minimum essential coverage using Part 3 of Forms 1095-C.

There have been numerous delays in implementing provisions of the ACA, and this delay is not the first regarding the mandatory filing of forms for reporting offers or provisions of minimum essential health coverage. While 2015 is the first year for which employers need to report relevant ACA compliance data, 2014 originally was to be the first year for which data were to be reported, but the IRS shifted the requirement to 2015 in Notice 2013-45.

Payroll practitioners and others who are responsible for filing the forms should use the extra time to ensure that their systems have accurately tracked wage and hour data necessary for determining which workers were full-time employees in months of 2015 for whom health coverage data need to be reported using the ACA forms. Under the ACA, an employee generally is considered full time if having worked on average at least 30 hours a week in a month.

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