What Health Coverage Forms Must Large Employers Complete and When?

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Question: Our business has determined that we’re an applicable large employer (ALE) subject to employer shared responsibility under Internal Revenue Code Section 4980H. As an ALE with a fully insured health plan, what forms do we need to complete to report on health coverage? When do we need to file them with the IRS?

Answer: You need to complete two separate forms:

  • Form 1095-C reports information about the coverage offered to full-time employees. The IRS needs this information to administer employer shared responsibility and premium tax credits.

    You must prepare a separate Form 1095-C for each employee who was a full-time employee for any month in 2015. Employees must receive a copy of the Form 1095-C reporting their 2015 information by March 31, 2016. (The original deadline for furnishing this information to employees was February 1, 2016, but the IRS extended the deadline at the end of 2015.)

 

  • Form 1094-C is used to transmit an ALE’s Forms 1095-C to the IRS. In addition to being a transmittal form, it also includes information that the IRS needs to administer employer shared responsibility. Form 1094-C is not furnished to employees. ALEs filing 250 or more Forms 1095-C with the IRS must transmit Form 1094-C and the accompanying Forms 1095-C to the IRS electronically.

    The due date for electronic filing for the 2015 tax year is June 30, 2016 (a three-month extension of the original March 31 deadline). The due date for filing paper Forms 1094-C and accompanying Forms 1095-C for the 2015 tax year is May 31, 2016 (a three-month extension of the original February 29 deadline).

Because your plan is fully insured, your health insurer will prepare Form 1095-B to report enrollment information for your plan. The insurer is responsible for filing this form with the IRS (along with the accompanying Form 1094-B transmittal) and furnishing a copy to enrolled employees. ALEs with self-insured plans have additional reporting responsibilities with respect to part-time employees and non-employees (such as retirees) actually enrolled in the plan. This enrollment information is needed to evaluate whether individuals have complied with individual shared responsibility under the tax code.

If you have questions about your responsibilities under the Affordable Care Act, contact your employee benefits or tax advisers.

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