The Affordable Care Act requirements for reporting employees and the respective benefit information still applies to all employers with 50 or more full-time or equivalent employees for the preceding calendar year.
Both mid-size and large businesses must implement and follow precise protocol for meeting these requirements by the governments' extended deadline. Here is the gist for most employer groups: • Employers will need to complete the “1095-C” reporting (even if sponsoring or participating in a fully insured or self-funded plan). The “1095-B” reporting is typically for insurance carriers. • Most large employers must submit their ACA reporting forms to the IRS each year (2018 tax year deadline: February 28th, 2019 or file electronically by April 2nd, 2019). • Employers will need to complete a 1095-C for each full-time employee and distribute to these employees by January 31st each year. (Note that the 1095 forms are very similar to the W2 forms issued to employees). • Basically, employers will send all of the 1095-C forms along with the 1094-C form (as a cover page) to the IRS by the deadlines mentioned earlier.
1095 Reporting & Post-Employment Participants
If you’re wondering if employers need to complete Form 1095-C for employees that had a COBRA qualifying event during the year, the answer is yes, they do. It should be noted that they only need to complete the form for those who had a qualifying event due to termination of employment or a reduction of hours. All other COBRA qualifying events should be reported by the employer’s insurer on their 1095-B reporting. When completing the 1905-C for an employee that had a termination of employment QE, in Part II of the form, for the months subsequent the termination (regardless if they enrolled in COBRA or not):
Line 14 should always use the Code 1H (no offer of coverage). An offer of COBRA is not an offering of coverage on Form 1905-C.
Line 15 should be left blank for those months.
On Line 16, Code 2A (employee not employed) should always be entered for the months after the termination of employment.
The Form 1905-C for an employee that had a reduction of hours QE differs from that of a terminated employee. For a reduction of hours QE, in Part II of the form:
On Line 14, opposite of a terminated employee, an offering of COBRA is always reported as an offering of coverage. Enter the same code that would be entered for any other active employee.
Line 15, enter the COBRA premium for the lowest cost self-only coverage that meets the minimum essential coverage requirements.
Who can help employers with ACA reporting responsibilities?
CobraHelp assists with the reporting needs of employers who must comply with the aforementioned ACA requirements pertaining to COBRA, FMLA, and retiree benefit enrollees. Our technology allows us to produce simple reports for employers, tax attorneys, accountants, and TPAs to utilize in completing the IRS forms annually and fulfilling their 1095 requirements under the Affordable Care Act. For more information about how CobraHelp can assist you, connect with us today!