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Affordable Care Act – Information Gathering for the Employer Mandate in 2015

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Under the Affordable Care Act, employers have been given shared responsibility to improve access to health insurance coverage in the United States. As a result, starting in 2015, Applicable Large Employers (ALEs) are required to offer affordable health coverage that provides a minimum level of coverage to their full-time employees or may be subject to a penalty. (For more information on determining whether your company is an ALE read our Aug. 31, 2015 alert.)

Also, effective in 2015, ALEs, as well as small employers that provide self-insured health coverage, are required to file information returns with the IRS and provide statements to employees.

Small employers that provide self-insured health coverage will use Form 1095-B to report information about the health insurance benefit to covered employees. The IRS will use the information to make a determination as to whether the individual has met his or her requirement to maintain Minimum Essential Coverage. A copy of the Form 1095-B will be sent to the IRS with Form 1094-B as a transmittal sheet. The due date for providing individuals 2015 Forms 1095 has been extended from February 1, 2016 to March 31, 2016. Employers now have until May 31, 2016 to file the 2015 forms with the IRS if not filing electronically, or until June 30, 2016 if filing electronically.

ALEs will use Form 1095-C to report health benefits offered (or not offered) to their full-time employees and their dependents, as well as self-insured health coverage for all employees. The IRS will use this information to make a determination as to whether the individual has met his or her requirements to maintain Minimum Essential Coverage and to determine whether the ALE has met its requirement to offer affordable health coverage that provides a minimum level of coverage to its full-time employees. A copy of the Form 1095-C will be sent to the IRS with Form 1094-C as a transmittal sheet. The due date for providing individuals 2015 Form1095-C has been extended from February 1, 2016 to March 31, 2016. Employers now have until May 31, 2016 to file the 2015 forms with the IRS if not filing electronically, or until June 30, 2016 if filing electronically.

The monthly information required to be reported is extensive and we recommend that you plan ahead to gather the information necessary. We also recommend that you ensure that you have identified how the forms will be prepared and submitted to employees and to the IRS. For further information on the reporting requirements for employers for the 2015 year, please contact your DHG tax advisor.



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