The IRS recently released draft forms and instructions for
employers to review in connection with the Affordable Care Act (“ACA”) employer
mandate. These forms are merely in
“draft” form and may change in the future, but they provide insight into the
scope of information that likely will be required from employers in the near
future.
Beginning in 2016 for the 2015 Plan Year, certain
employers must file Forms 1094-C and 1095-C in order to meet their reporting
requirements under the statute. The
purpose of the reporting requirement is to notify the government about whether
the employer is meeting its health coverage obligations under the ACA.
The ACA requires employers with 50 to 99 “full time
equivalent” employees to offer health insurance to all full time employees by
January 2016. Employers with over 100
“full time equivalent” employees must offer health insurance to all full time
employees by January 2015. Employers
that fail to meet these requirements are subject to a fine.
Form 1094-C is used to report to the IRS a summary of the
information being provided on a Form 1095-C as to each employee. A copy of the draft Form 1094-C can be found here. Form 1095-C is used to report information
about each employee’s health insurance coverage. A copy of the draft Form 1095-C can be found here. A copy of the draft instructions for filling
out both forms can be found here.
For more information on the ACA employer mandate, please
contact Connell Foley’s labor and employment law attorneys.
