The Affordable Care Act has been a rather confusing piece of legislation for many employers, as it’s impacted what they are required to do and report to the IRS regarding their health insurance plan. Read on for a list of 2016 reporting requirements, the extended IRS reporting deadlines, and some helpful resources to prepare for what is to come:
To prepare for reporting under Section 6056 of the Internal Revenue Code, Applicable Large Employers will need to:

  • Determine the health insurance coverage offered and provided to employees and their dependents in 2015
  • Identify full-time employees for each month and track health coverage information in 2015
  • Applicable large employers must file an annual return with the IRS in 2016 using Forms 1094-C and 1095- C, reporting whether they offered health insurance, and if so, what type of insurance was offered for the 2015 calendar year.
  • Applicable large employers must also provide a statement (usually by providing a copy of the employee’s Form 1095-C) to each full-time employee who was employed or offered medical coverage any time within the calendar year, and to non-full-time employees who were offered coverage under a self-insured plan.
  • Applicable large employers who are required to file 250 or more information returns must electronically file the 1094-C report of coverage information and data reported on Forms 1095-C. ALEs filing fewer than 250 information returns may file paper returns, but the deadline is sooner than electronic files.

Reporting requirements apply to employers that sponsor self-insured coverage, even if the employer is not an applicable large employer.

ACA REPORTING DEADLINES
Extensions Issued 12/28/15

Form 1095-C to employees by March 31, 2016

Form 1094-C and 1095-C data to IRS by May 31, 2016 (for paper returns) or June 30, 2016 (if filing electronically)

Resources
IRS Article: Questions and Answers on Reporting of Offers of Health Insurance Coverage by Employers (Section 6056)
IRS Article: Affordable Care Act Tax Provisions for Employers
IRS full statement regarding extension of the deadline extension for 2015 information reporting