ACA Reporting Year-end Checklist for Applicable Large Employers (ALEs)

aca-compliance-checklistWith reporting deadlines approaching for the 2015 tax year, employers of all sizes should be clear what their reporting responsibilities are. Suffice it to say that all employers who offer health care coverage will have some responsibilities to report, regardless of size.

Below is a brief self-check list of topics employers can use ensure they are familiar with the subject and can help them prepared to report. It’s important to note that even though your company may outsource payroll and timekeeping, that may not necessarily imply that your outsource company includes ACA reporting as part of that service. Check with our Payroll Customer Service Team, or your CPA for more information.

Employers of Any Size That Offer Health Insurance Coverage:

  • If you are reimbursing any active employee for the cost of health insurance they purchased in the individual market—STOP; the arrangement violates the ACA market reforms.
  • If you have ownership in more than one business, confirm that these businesses are not a controlled group or an affiliated service group, to make sure these businesses are not treated as a single employer with each business being treated as an “applicable large employer.”

Employers with 100 or More Full-Time or Full-Time Equivalent Employees (FTEs):

  • If you are relying on any transition relief for your 2015 plan year check the applicable box on line 22 of your Form 1094-C.
    • Forms 1095-C must be furnished to employees by March 31, 2016*. Forms 1094-C and 1095-C must be filed with the IRS no later than May 31, 2016* (June 30, 2016* if filing electronically).

Employers with More Than 50 FTEs But Less Than 99:

  • The reporting requirements described above for larger employers apply to you even if you are not subject to the ACA employer mandate for your 2015 plan year due to a transition relief exemption.

*The IRS has extended the due dates for furnishing and filing 2015 ACA information forms as follows:

  • The deadline for furnishing individuals the 2015 Forms 1095-B and 1095-C is extended from February 1, 2016 to March 31, 2016.
  • The deadline for filing with the IRS the 2015 Forms 1094-B, 1095-B, 1094-C, and 1095-C is extended from March 31, 2016 to June 30, 2016 if filing electronically and from February 29, 2016 to May 31, 2016 if not filing electronically.