The ACA: 2015 Changes For Employer Groups

In 2015, Sponsors of self-funded health plans will have new responsibilities for filing paperwork relating to the employer mandate and the individual mandate, due to provisions of the Affordable Care Act.

For the 2015 tax year, employers will be required to file forms that report compliance, and employees will need these forms to file individual tax returns and prove individual compliance. These new responsibilities are outlined in IRS Section 6055 and IRS Section 6056. Although required paperwork will not be filed with the IRS until 2016, employers need to be prepared now.

What do Employers have to do now?

  • Measure employee hours: Ensure that you have an established policy and procedures to measure hours of service for variable hour (part time, PRN, etc.) employees.
  • Make Offers of Coverage to eligible employees: Begin making Offers of Coverage to variable hour employees who average 30 hours of service per week and above during their designated measurement period. Depending on the standard measuring period selected, most calendar-year plans should have already begun making these offers. Non-calendar year plans should be prepared to begin making offers by the first day of their 2015 Plan Year.
  • Collect dependent SSNs: Begin the process of collecting social security numbers for all dependents of covered Employees. Employers should have gathered all SSNs by Dec. 1, 2015, in order to have sufficient time to produce the documents that will be filed in early 2016.
  • Update HR policies: Update all HR policies and procedures and Employee Handbooks to reflect how the Employer is complying with the Employer Mandate.

When do Employers have to report?

  • Employers will report 2015 information in 2016. The deadline for filing this information will be the same as it is for W-2 reporting.

What do Employers have to report?

Forms and instructions are still being finalized by the IRS. They will not be released until later in 2015. The following information is based on draft forms and instructions issued last year. Please be aware, these forms may be altered or renamed prior to final release.

1094B For self-funded groups with less than 50 employees. This is a cover sheet that includes basic Employer data, such as EIN and contact person.
1095B For self-funded groups with less than 50 employees. This lists individual coverage. A separate 1095B is completed for each covered employee. One copy is provided to the employee and one is filed with the IRS.
1094C For self-funded groups with more than 50 employees. This is a cover sheet that includes basic Employer data, such as EIN and contact person, as well as the number of fulltime employees and the total number of employees for each month of 2015.
1095C For self-funded groups with more than 50 employees. It documents compliance for the employer mandate AND the individual mandate. A separate 1095C is completed for each full-time employee, whether or not they took the coverage. One copy is provided to the employee and one is filed with the IRS.

What about self-funded employers with fewer than 100 employees?

  • Employers with 50 – 99 FTEs may be exempt from the employer mandate in 2015 through transitional relief. They are still required to file because employees will need their individual report when filing individual income tax returns for 2015.
  • Employers with fewer than 50 FTEs are exempt from the employer mandate. But they still must file the applicable forms regarding covered employees so their employees will get statements to use when filing individual income tax returns for 2015.

For more assistance:

  • HF recommends working with your payroll vendor for assistance in measuring hours and in completing the correct IRS forms.
  • If you would like additional information, visit the section of the IRS website devoted to Affordable Care Act provisions, http://www.irs.gov/Affordable-Care-Act/Employers
  • We will continue to monitor developments throughout 2015 and will alert you to any significant changes.