Reporting Requirements Revisited

Despite delays in the implementation of the Affordable Care Act’s (ACA) reporting requirements, 2016 is the year where the rubber hits the highway.  IRS Code section 6055 (Minimum essential coverage) and 6056 (Large employer reporting) are both required for the 2015 plan year.  What that means is that if you are a large employer (More than 50 Full-Time Employees-including Full-Time Equivalents (FTE)), section 6056 requires that you submit form 1094-C (Transmittal form) and 1095-C (Individual coverage summary), providing information necessary for the IRS to confirm coverage offered by the company is in compliance with the ACA requirements and properly identifies employees who are covered by the plan.  Section 6055 covers Self-Insured employers and Health Insurers.  For fully insured groups, the Health Insurer has the responsibility to report on behalf of the plan and to provide notice to each covered employee on form 1094-C (1095-C for Applicable Large Employers).  For large employers, the employer remains responsible for reporting the transmittal form, notwithstanding the fact that the health plan is “Fully Insured.”

Confused yet?  Well, the regulations are not easy to understand and implement, therefore, the purpose of this communication is to make you aware and to encourage you to ask questions regarding compliance.  This communication only scratches the surface of what you need to know.  Keep in mind, measuring your full-time employees is required on a monthly basis. Now is the time to be curious.

Why?  Penalties for non-compliance are stiff!  Employers that do not submit an annual return or provide individual statements to all full-time employees may be subject to a penalty up to $250 per return (Employee), with a maximum annual penalty of $3 million.

There are companies providing assistance for this reporting requirement and even they are just starting to figure out how to appropriately assist, based on final regulations that have only been available for a relatively short period of time. 

Like all other aspects when it comes to the government collecting data, it’s not simple and penalties for non-compliance are stiff, therefore, start your preparation process now.

About Hipskind Seyfarth Risk Solutions

Hipskind Seyfarth Risk Solutions offers a wide-range of insurance products for individuals and businesses of all sizes. HS Risk Solutions, located in Chicago, provides expertise in the area of health and ancillary benefits and property and casualty insurance for businesses and individuals. For more information, visit HS Risk Solutions website at www.hsrisksolutions.com or on Facebook atwww.facebook.com/HSRiskSolutions.

DISCLAIMER: Hipskind Seyfarth Risk Solutions is not providing tax advice in the above post and therefore should not be deemed as such.