2015 is coming to an end and there are new requirements in regards to Health Care Reform. In January of 2016, large employers (those with 50 or more full-time equivalent employees) are required to begin employer mandate reporting for the 2015 tax year. Additionally, small employers (less than 50 full-time equivalents) that have a self insured health plan will have to begin employer mandate reporting for the 2015 tax year. So what information must a large (small self insured) employer begin tracking in 2015?
Employers with 100+ full time equivalent employees in 2015 with a fully insured health plan:
Employer mandate penalties begin in 2015 for large employers with 100 or more full-time equivalent employees. Large employers are required, under Section 6056 of the tax code, to complete and submit one Transmittal Form (IRS Form 1094-C) and, for each employee, an Employee Statement (IRS Form 1095-C – top half only). It may help you to think of the 1094-C as similar to the W-3 (a transmittal form) and the 1095-C as similar to the W-2 (a separate return for each full time employee).
Employers with 50-99 full-time equivalent employees in 2015 with a fully insured health plan:
Even though the regulations provide transitional relief from the employer mandate penalties in 2015 for most midsized employers, these employers still are required to perform certain reporting tasks under Section 6056. Midsized employers must file a Section 6056 Transmittal (IRS Form 1094-C) to prove that the employer in fact meets the requirements for the transitional relief. As long as the transitional relief requirements are met, employer mandate penalties will not begin for these midsized employers until 2016. Midsized employers will also be required to file an Employee Statement (the top half of IRS Form 1095-C) for each Full Time employee annually.
Employers with 50+ full time equivalent employees in 2015 with a self-insured health plan:
Employers with self-insured health plans are required to perform both the employer reporting requirements (Section 6056) and the insurer reporting requirements (Section 6055). So employers with a self-insured plan are required to complete both the top and bottom half of the IRS Form 1095-C. (The top half of the form includes the Section 6056 reporting information and the bottom half of the form includes the Section 6055 reporting information.) These employers are also required to complete the transmittal form (IRS Form 1094-C). This guide is only intended to cover the Section 6056 (employer) reporting requirements, not the Section 6055 (insurer) reporting requirements.
Employers with less than 50 full time equivalent employees in 2015 with a self-insured health plan:
Employers with self-insured health plans and less than 50 full time employees are required to complete the "B" Forms. Both the 1094-B transmittal and the 1095-B for each participant in the self-insured health plan must be completed.
M&H will be assisting employer's with these filing requirements this year in January of 2016 for the 2015 calendar year. We will provide more details about filing information on our next post.
