Get Ready: Final IRS Regs for Reporting Employer Health Coverage

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For calendar years after December 31, 2014, large employers (50 or more employees) must file an Information Return with the Internal Revenue Service (IRS) and furnish Statements to all full-time employees (30 or more hours per week), regardless of whether they have been offered coverage.

Similar to a separate Forms W-2 and W-3, filed for each employee, these regulations provide that a separate return is required for each full-time employee, accompanied by a single transmittal filed for a given calendar year.

Information required to be reported to the IRS (Form 1094-C)

  1. The name, address and employer identification number (EIN) of the employer;
  2. The name and telephone number of the employer’s contact person;
  3. The calendar year for which the information is reported;
  4. A certification as to whether the employer offered to its full-time employees (and their dependents) the opportunity to enroll in coverage that met ACA standards;
  5. The months during the calendar year for which coverage was offered;
  6. Each employee’s share of the lowest cost monthly premium (self only) for coverage offered to full-time employees, by calendar month;
  7. The number of full-time employees for each month during the calendar year; and
  8. The name, address and tax identification number (TIN) of each full-time employee during the calendar year and the months, if any, during which the employee was covered under the plan.

In lieu of reporting full-time employees, an employer may choose to certify that 98 percent of full-time employees (and their dependents) where offered coverage.

Reports must be filed on or before February 28 (March 31 if filed electronically) of the year following the calendar year in which coverage is provided. (On or before February 28, 2016 for the first filing)

Statements furnished to full-time employees (Form 1095-C)

  1. The name, address and employer identification number (EIN) of the employer; and
  2. The information required to be shown in the 6056 Return with respect to the full-time employee.

Statements must be furnished on or before January 31 of the year following the calendar year in which coverage is provided. (On or before January 31, 2016 for the first statement)

If mailed, the statement must be sent first-class mail to the full-time employee’s last known permanent address or, if not known, the employee’s temporary address.

With an employee’s written and knowing consent, statements can be furnished electronically.

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