The Affordable Care Act (ACA) imposes significant information reporting responsibilities on employers starting with the 2015 calendar year

The IRS has issued draft 2015 forms and instructions that will be finalized later this year.

Information returns

The new information reporting system is similar to the current Form W-2 reporting system in that an information return (Form 1095-B or 1095-C) will be prepared for each applicable employee, and these returns will be filed with the IRS using a single transmittal form (Form 1094-B or 1094-C). Electronic filing is required if the employer files at least 250 returns. Employers must file these returns annually by Feb. 28 (March 31 if filed electronically). Therefore, employers will be filing these forms for the 2015 calendar year by Feb. 28 or March 31, 2016. A copy of the Form 1095, or a substitute statement, must be given to the employee by Jan. 31 and can be provided electronically with the employee’s consent. Employers will be subject to penalties of up to $500 per return for failing to timely file the returns or furnish statements to employees.

The filing requirements are based on an employer’s health plan and number of employees.

Form 1095-B (Health Coverage) and Form 1094-B (Transmittal of Health Coverage Information Returns) will be filed by insurance companies to report individuals covered by insured employer-sponsored group health plans. Small employers with self-insured health plans will also use Form 1095-B and Form 1094-B to report the name, address and Social Security number (or date of birth) of employees and their family members who have coverage under the self-insured plan. Employees who are offered coverage, but decline the coverage, are not reported.

Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) and Form 1094-  C(Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) will be filed by applicable large employers. These forms will be required if the employer offers an insured or self-insured group health plan, or does not offer any group health plan.

Applicable large employers are those that had, on average, at least 50 full-time employees (including full-time equivalent employees) during the preceding calendar year. Full-time employees are those who work, on average, at least 30 hours per week.

Small employers with fewer than 50 full-time employees (including equivalents) will be required to file Forms 1095-C and 1094-C if they are members of a controlled or affiliated service group that collectively has at least 50 full-time employees (including equivalents). Companies could be in a controlled or affiliated service group if they have common owners, provide services for each other or work together to provide services to third parties.

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