By Junlin Huang, CPA
The Tax Cuts and Jobs Act (P.L. 115-97) repeals the individual mandate effectively beginning after December 31 ,2018. However, the Affordable Care Act (ACA) employer mandate remains in effect for 2019 and beyond, which means employers are still required to provide affordable coverage, and furnish and file a Form 1095 -C with the IRS.
Who must comply?
ACA requires information reporting by Applicable Large Employers (ALEs) on the health coverage offered to their full-time employees. An ALE is defined as having at least 50 full-time employees, including full-time equivalent employees, who work at least 30 hours a week. There are stiff penalties associated with non-compliance.
Information to be Reported to the IRS
Employers must report information to the IRS including identification of the ALE, identification of full-time employees who receive health coverage, and duration of the coverage.
How Do I Report?
Each ALE Member must file a Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.
Self-insured employers who sponsor self-insured group health plans must comply with the information reporting requirement whether or not they are ALEs. Self-insured ALEs still must use Forms 1095-C and 1094-C. However, these non-ALEs use Form 1095-B, Health Coverage, and Form 1094-B. Transmittal of Heath Coverage Information Returns to fulfill the information reporting requirement.
What is the Deadline for 1095?
For 2019 tax year. Forms 1095-C and 1094-C are required to be filed by February 28, 2020 if filling on paper (or March 31 ,2020 if filling electronically), even if the employer maintains a non-calendar year health plan. Employers can apply for 30–day extension of time to file by completing Form 8809, Application for Extension of Time to File Information Returns.
Let us Help!
Let us take the guesswork out of staying in compliance with the ACA Employer Mandate. The professionals at Harris CPAs can prepare, and if applicable, electronically file the Form 1095-C on your behalf. Please contact (208) 333-8965 for more info.
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