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ACA Reporting Requirements Become Effective in 2016
Employers subject to the Affordable Care Act's (ACA) employer mandates will not have to comply with the reporting requirements concerning health care coverage they offer to their employees.
The ACA amended the Internal Revenue Code to require that "applicable large employers" (employers with 50 or more full-time and full-time equivalent employees) file information returns with the IRS detailing the coverage that they did or did not offer to full-time employees in the preceding year. These employers also must provide statements to employees about the coverage they were or were not offered.
Applicable large employers (ALE) must file their information returns with the IRS on or before February 29, 2016, or by March 31, 2016, if they file the information returns electronically (employers filing more than 250 returns must do so electronically). Applicable large employers must provide the required statements to their employees by February 1, 2016.
Final versions of the 2015 health care information reporting forms are now available (reference web links below). The Internal Revenue Service has released the final versions of two key 2015 forms and the related instructions that employers and insurers will send to the IRS and individuals this winter to report health care coverage they offered or provided. The health care law requires certain employers and providers to submit the 2015 forms to the IRS and individuals in early 2016. Though the forms were available for voluntary use in tax-year 2014, the upcoming tax season will be the first time that reporting is mandatory.
Now is the time to determine ALE status (access link below to determine your status now). Employers that are applicable large employers should be taking steps now to prepare for the coming filing season. You must determine your ALE status each calendar year based on the average size of your workforce during the prior year. If you had at least 50 full-time employees, including full-time equivalent employees, on average during 2014, you are most likely an ALE for 2015.