
INSIGHTS FOR HEALTH CARE	SEPTEMBER 8, 2015

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ACA Reporting Requirement: Start Planning Now

While December 31, 2015, is still months away, that date will bring a new specialized Affordable Care Act (ACA) reporting requirement for large employers, defined under the ACA as those with 50 or more full-time equivalent employees, including smaller employers that reach the 50 or more level due to consolidation or being part of a larger controlled group, and employers with self-funded insurance plans.

The new reporting requirement, due to employees by January 31, 2016, and to the Internal Revenue Service on February 29, 2016, if paper filed or March 31, 2016, if e-filed, provides details for the IRS, the employer, and employees about the offers of health coverage the employer made to full-time employees. The information gathered and reported via IRS Forms 1094-C and 1095-C will allow the IRS to follow compliance, determine any penalties required under the ACA employer mandate, while also allowing an employee to determine eligibility for subsidies if the employee purchases coverage in the marketplace. Small employers with self-funded plans share a similar reporting requirement using forms 1094-B and 1095-B.

The new health coverage reporting is made on a calendar year basis, regardless of the health plan year end. It also requires month by month reporting information as the status of the employee can change within the reporting year.

Complex Requirements

At first glance, the reporting forms could suggest to some employers that they can complete the information gathering and filing requirements without assistance. However, the ability to identify the data to be collected, track the necessary information consistently, and incorporate changes to coverage and funding during the full calendar year make the monthly reporting requirement complex at best, even for those educated in the rules for reporting and utilizing specially designed computer programs.

The IRS has noted, as they do with most new reporting requirements, that the penalties for failure to file or furnish complete and accurate information (penalties range from $50 per form to $250 per form) may be waived for those employers acting in good faith. For others, they will need to deal with the penalties based on their facts for not complying with the rules.

A quick read of the instructions for the new reporting forms amplifies the complexity of understanding the terms used, even as related to the classification of those required to file. Then, knowing what information needs to be gathered, where to get that information and formatting it to fit the reporting form has created the need for the development of computer systems specifically designed for this ACA reporting function.

Time truly is of the essence in understanding and planning how to comply with this reporting requirement, as the time between now and the first reporting date will evaporate quickly.

More Resources

Our health care reform professionals have been working to develop plans on the approach to information gathering and the requirement to file these new health coverage reporting forms and will be providing additional information related to the overall process. If you have questions, please visit our health care reform website, contact your Eide Bailly service provider or reach out to our health care reform team at healthcarereform@eidebailly.com or 855.220.8634.

This publication is produced and published by Eide Bailly and distributed with the understanding that the information contained does not constitute legal, accounting or other professional advice. It is not intended to be responsive to any individual situation or concerns as the contents of the publication are intended for general informational purposes only. Readers are urged not to act upon the information contained in this publication without first consulting competent legal, accounting or other professional advice regarding implications of a particular factual situation. Questions and information for publication can be submitted to your Eide Bailly representative. To request reprints of this publication, send a written request to RequestReprints@eidebailly.com.
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