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Employer Reporting Scenarios by Group Size and Plan Type

Beginning in 2016, large employers and employers who offer self-funded plans are responsible for reporting information to their employees. The scenarios below outline employers’ obligations by circumstance. Read our Employer Reporting Requirements Under ACA article for more information, deadlines, and resources for the requirements.

Small employer who offered no coverage last year. No reporting responsibilities.

Small employer who offered only fully insured plans last year. No reporting responsibilities. The health insurer will provide Form 1095-B statements to each individual who was covered by the plans at any point in 2015.

Small employer who offered a self-funded plan last year. The employer provides Form 1095-B statements to each employee who was covered by the plan at any point in 2015. The statement identifies each member of the family covered and the months of coverage. The employer should obtain the data from their plan administrator (carrier / TPA). If the plan administrator does not provide access to this data, the employer can piece it together manually using their internal records (historic employee enrollment forms). The employer files a Form 1094-B transmittal with the IRS along with each Form 1095-B statement.

Intro: An Applicable Large Employer (ALE) is an employer who averaged 50 or more full time and equivalent employees in the preceding calendar year. For reporting due in 2016 about coverage in 2015, the preceding calendar year is 2014. The number of employees in companies that are related to other companies under common ownership, control, or affiliation are counted together to determine the ALE status of each company. Each related company must report separately. Note, a company with 5 employees could be subject to the large employer requirements by virtue of its related ownership with other companies.

Applicable Large Employer who offered no coverage last year. The employer provides Form 1095-C statements to each employee who was full time at any point during 2015. The statements who that the employer offered no coverage. The employer files a Form 1094-C transmittal with the IRS along with each Form 1095-C statement.

Applicable Large Employer who offered only fully insured plans last year. The employer provides Form 1095-C statements to each employee who was full time at any point during 2015. The employer completes only Parts I and II of each form (top half of first page). The employer obtains the information from its payroll system. The health insurer will provide separate Form 1095-B statements to each individual who was covered by the plans. The employer files a Form 1094-C transmittal with the IRS along with each Form 1095-C statement.

Applicable Large Employer who offered a self-funded plan last year. The employer provides Form 1095-C statements to each employee who was full time and/or each employee who was covered by the plan at any point in 2015. The employer completes all sections of each form. Part I is information about the employer. Part II is information about the offer of coverage, which is obtained from the payroll system. Part III is information about who was covered by the plan and when. The employer should obtain this data from their plan administrator. The employer files a Form 1094-C transmittal with the IRS along with each Form 1095-C statement.

This is an overview of the forms as it pertains to employer obligations.

  • Form 1095-B: Individual statements. Used if the employer offered a self-funded plan and is not an Applicable Large Employer.
  • Form 1094-B: Employer transmittal (cover sheet) provided to IRS with Form 1095-B statements.
  • Form 1095-C: Individual statements. Used by Applicable Large Employers. Employer completes Part III only if it offered a self-funded plan.
  • Form 1094-C: Employer transmittal provided to IRS with Form 1095-C statements.
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