You need to be aware that there are two levels to compliance:
Offering health insurance of a certain quality to full-time employees
Proving the right offer was made to the right employee at the right time.
That’s easy, right?
There are plenty of complexities to consider, such as who is “full-time” according to ACA classifications and what offers of health plans meet ACA standards. There also are plenty of consequences: If you don’t comply with the first level, there are coverage penalties. If you don’t comply with the second level, there is an IRS non-filing penalty. None of the penalties can be deducted as business expenses.
But there is some hope. For Tax Year 2015, the IRS is not going to assess coverage penalties to companies that have 50-99 full-time employees (including equivalents). But, to be considered ACA-compliant for Tax Year 2015, all companies that are ALEs must:
Produce statements for full-time employees about what type of coverage was or was not offered. This form is called a 1095-C.
File copies of these statements with the IRS. The transmittal form is called a 1094-C.
There is a quirk to producing and filing these statements: This is not just a trip down to the local library to pick up a booklet with the proper forms in it. The 1095-C form, which is the most detailed form ever required of U.S. employers by the IRS, breaks down a year’s worth of payroll and benefits data by month.
The only similarity to a W-2 is the date it must be given out. For companies that are fully insured, this means providing a 1095-C form to every full-time employee. For companies that are self-insured, this means providing a 1095-C form to every covered employee.
The recordkeeping that goes into producing 1095-Cs accurately is not a job for spreadsheets.
The clock is ticking: 1095-C forms are due to employees February 1, 2016 (the same day as W-2s).
One call to Integrity Data can do all the heavy lifting for this new compliance burden. We have a simple-to-use ACA tracking and reporting solution that can produce the forms for your employees and the IRS, no matter what payroll or ERP system your business uses. Beyond the yearly reporting needed for regulatory compliance, our system does deep internal monthly reporting for ACA penalty risk management.
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