Back in November, we published a blog post notifying large employers that the Employer Shared Responsibility provision of the Affordable Care Act (ACA) would take effect in 2016. The provision requires businesses that employed at least 50 full-time employees or full-time equivalents (FTEs) in 2015 to report on the health insurance coverage they offered to their staff.
Employers report the health coverage they provided using Forms 1095-C and 1094-C. However, the IRS recently delayed the due dates for these forms.
The 1095-C due date is now March 31, 2016: 1095-C forms (Employer-Provided Health Insurance) are provided to employees and outline the coverage offered to them in 2015, including the lowest-cost premium they could select and the months of the year the coverage was available. Employees submit their 1095-C form with their individual tax filing.
Businesses were previously required to mail 1095-C forms to each employee that was eligible for health insurance coverage in 2015 by January 31, 2016.
The 1094-C due date is now May 31, 2016: The 1094-C form (Transmittal of Employer-Provided Health Insurance) is a cover letter businesses send to the IRS that consists of their contact and identification information, as well as a list of eligible employees who were sent 1095-C forms.
Businesses were previously required to submit their 1094-C form to the IRS by February 29, 2016.
Missing these due dates or making mistakes on these forms can result in a minimum penalty of $100. Fortunately, large employers now have an additional two months to meet their requirements under the Employer Shared Responsibility provision. If you use payroll software or work with an outsourced payroll provider, there’s a good chance they’ll automatically generate these forms for you, much like they do with W-2 and 1099 forms.