Large Employers: Time to Start Planning for ACA Information Reporting

With the U.S. Supreme Court’s June 25 decision to uphold the Affordable Care Act (ACA) yet again, employers subject to the act’s information reporting provision can no longer afford to put off planning in the hope that the requirements might go away.

Beginning in 2016, “large” employers as defined by the act (generally employers with 50 or more full-time employees or the equivalent) must file Forms 1094 and 1095 to provide information to the IRS and plan participants about health coverage provided in the previous year (2015).

Fortunately, recent IRS guidance helps clarify the reporting requirements. Furthermore, a new IRS Q&A document addresses more specific issues that may arise while completing the forms.

Keep in mind that, while some “midsize” employers (generally employers with 50-99 full-time employees or the equivalent) can qualify for an exemption from the play-or-pay provision in 2015 if they meet certain requirements, these employers still will be subject to the information reporting requirements.

If your organization is among those that are required to file Forms 1094 and 1095, and you need assistance in complying with the requirements, please reach out to us.