Affordable Care Act: What Your Business Needs to Know

The deadline for health plan sponsors to provide postmarked or furnished Forms 1095-B and 1095-C to their employees is March 2, 2022. Not only must these forms be complete, an Applicable Large Employer (ALE) must file a copy of the Forms 1095-C, together with a Form 1094-C, with the IRS. If your business is filing by paper, the earlier deadline is February, 28, 2022 (this is only permitted for employers with fewer than 250 Forms 1095-C).

 

As for the reporting requirements for Applicable Large Employers (ALEs), a business is considered to be an ALE in 2021 if it averaged 50 or more full-time equivalent employees during 2020.

An ALE must provide a Form 1095-C to any employee who was considered full-time for any month in 2021. (This is where it gets tricky, for these purposes, “full-time” is defined by the Affordable Care Act.)

In addition, an ALE must file a copy of the Form 1095-C, together with Form 1094-C, to the IRS.

 

Requirements for the reporting of employers offering a Self-Funded Major Medical Plan.
These employers, large or small, have two compliance options.

  • Option One
    • The employer must provide Form 1095-C or Form 1095-B to any individual who was covered by the self-funded plan in 2021. Please note that this is not just for full-time employees. The deadline for furnishing these forms is March 2, 2022.
    • In addition, the employer must file copies of the individual forms, together with a Form 1094-C or 1094-B, with the IRS. For paper filers, the deadline is February 28, 2022. For electronic filers, the deadline is March 31, 2022.
    • Important: If the employer is subject to state reporting, Option One is generally preferable. Furnishing Forms 1095-C or 1095-B will often satisfy the state requirement to notify individuals.
  • Option Two
    • The employer must post a notice on its website stating that individuals may obtain a Form 1095-C or 1095-B upon request. The notice must include both an email address and a physical address where such requests may be sent, as well as a phone number that individuals can use to contact the employer with questions. The deadline for posting the notice is March 2, 2022. The employer must also furnish the appropriate form to an individual within 30 days of receiving a request.
    • The employer must file copies of the individual forms, together with the Form 1094-C or 1094-B, with the IRS.
    • It is important to note that while this option largely allows the employer to avoid a mailing all of the forms to employees, the employer still needs to be able to generate the individual forms.

The process for ACA reporting is complex. It requires going through numerous documents, meeting deadlines, and there are set requirements.

Your ACA reporting doesn’t have to be challenging. If you have any questions about the process of filing your ACA reports, we’ve got you covered.

At Payroll Solutions, we offer innovative solutions for ACA and EEOC compliance. Our team of experts have the skills and knowledge to improve your ACA reporting experience. We recommend that you contact us to learn more.

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