Overview of New IRS Reporting Requirements
Posted on: May 21, 2015Categories: HR & ComplianceAs part of the employer mandate, new IRS reporting requirements take effect for the first time in 2015 for employers that had 50 or more full-time employees, including full-time equivalents, during 2014. This is a summary overview of the reporting requirements to assist your organization with preparations during 2015.
IRS Forms & Deadlines:
The key forms for employers are IRS Form 1094-C (IRS submittal) and IRS Form 1095-C (submittal to full-time employees*). The specific forms and applicable deadlines are:
| Employer size* | Type of Group Health Plan | Reporting Required? | Specific Forms & Deadlines |
| 1-49 | None | No | n/a |
| 1-49 | Fully insured | No | n/a |
| 1-49 | Self-funded | Yes | Form 1095-B to full-time employees** by 1/31/16Form 1094-B to IRS by 2/29/16 (3/31/16 if electronic) |
| 50+ | None | Yes | Form 1095-C to full-time employees by 1/31/16Form 1094-C to IRS by 2/29/16 (3/31/16 if electronic) |
| 50+ | Fully insured | Yes | Form 1095-C to full-time employees by 1/31/16Form 1094-C to IRS by 2/29/16 (3/31/16 if electronic) |
| 50+ | Self-funded | Yes | Form 1095-C*** to full-time employees by 1/31/16Form 1094-C to IRS by 2/29/16 (3/31/16 if electronic) |
* Employer size is based on the calculation of full-time employees (130 hours per month) plus full-time equivalents during any consecutive 6+ month period during the 2014 calendar year
** Full-time employees include those that had full-time or eligible status for at least one month during 2015. Part-time employees, or new variable employees still in Initial Measurement Period, are not required to receive 1095-C.
*** Self-funded plan sponsors must complete Part III on Form 1095-C, including enrollment information for spouses and dependents. Fully insured plans are exempt from Part III.
Key data that needs to be tracked for 2015 calendar year:
- Number of full-time employees for each calendar month
- Number of total employees for each calendar month
- For each full-time employee, status by month (employed; offered coverage; enrolled or waived)
- Applicable cost of coverage for each full-time employee (lowest cost EE share of qualifying coverage)
- (Self-funded plans) For each enrolled spouse/dependent – name, address, SSN or DOB, months covered
How Clarke & Company will help:
Contact us anytime if you need further details or assistance. We will be hosting training sessions and webinars during 2015, to be announced soon. Our online enrollment system (EmpowHR) as well as our data builds for those employers not on EmpowHR will be able to complete reporting requirements for your company. Later this year, we will distribute a Quick Reference Guide for completing the forms, including practical advice and a “cheat sheet” of applicable codes.
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