New IRS reporting requirements for Applicable Large Employers (ALE) under the Affordable Care Act (ACA)

If you are an “Applicable Large Employer” with over 50 full time employees (including full time equivalents) you will be required to complete certain new IRS forms in early 2016 to be distributed to each employee by January 31st and submitted to the IRS by February 29, 2016, or March 31, 2016, if filing electronically.

Form 1095-C must be distributed to each employee and 1094C is submitted to the IRS. The IRS released drafts of the two required forms on June 16th so you have an idea of what will be required.

Here is the IRS link for instructions:

See below for a couple of excepts from the IRS instruction guide:

Purpose of Form

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 sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C must be used to report to the IRS summary information for each employer and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee. In addition, Forms 1094-C and 1095-C are used in determining whether an employer owes a payment under the employer shared responsibility provisions under section 4980H. Form 1095-C is also used in determining the eligibility of employees for the premium tax credit. Employers that offer employer-sponsored self-insured coverage also use Form 1095-C to report information to the IRS and to employees about individuals who have minimum essential coverage under the employer plan and therefore are not liable for the individual shared responsibility payment for the months that they are covered under the plan.

Who Must File

An employer subject to the employer shared responsibility provisions under section 4980H must file one or more Forms 1094-C (including a Form 1094-C designated as the Authoritative Transmittal, whether or not filing multiple Forms 1094-C), and must file a Form 1095-C (or a substitute form) for each employee who was a full-time employee of the employer for any month of the calendar year. Generally, the employer is required to furnish a copy of the Form 1095-C to the employee.

Hope this info helps you prepare for this new IRS requirement under the Affordable Care Act.