The Ultimate ACA Compliance 2017 Checklist
The Affordable Care Act (ACA) has undergone several significant changes since the law was enacted in 2010. Many of these key updates include design changes, wellness program incentive, and of course the Employer Shared Responsibility Mandate. This ACA compliance 2017 checklist covers changes taking effect during the 2017 year-end tax season.
To prepare for 2018, all Applicable Large Employers (ALEs) should review new requirements and develop an ACA reporting and compliance strategy.
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Highlights
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ACA Changes for 2018
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Other Expected Changes:
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ACA Compliance 2017 Checklist |
The Affordable Care Act requires Applicable Large Employers (ALEs) to report information to the IRS and to their full-time employees regarding employer-sponsored health cover offered. The IRS uses the information ALEs report to verify employer-sponsored coverage and administer the Employer Shared Responsibility Mandate. (Code Section 6056)
Section 6055 is used to determine whether individuals are covered by minimum essential coverage. This section calls for the health plan issuer or insurance company to provide Form 1095-B and Form 1094-B to show the individual’s coverage levels. This will also prove the if an individual is fully insured through their employer or if they receive coverage through a spouse or parent.
These ACA reporting requirements took effect in 2015, and all returns reporting coverage offered or provided in 2017 are due early 2018. ACA Form 1095-C and Form 1094-C must be filed with the IRS by February 28th ( or April 2nd, if filed electronically) of the year following the calendar year to which the returns relate. ACA Form 1095-C generally must be provided to employees no later than January 31st of the following yes coverage was provided. For the 2017 calendar year, all individual statement must be furnished no later than March 2nd, 2018.
Applicable Large Employers (ALEs) with self-funded health care plans are required to comply with all reporting obligations, while ALEs with insured plan need to only file section 6056. The IRS simplify this process by allowing ALEs with self-insured plans to combined single for to reporting all information under Section 6055 and 6056.
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ALEs:
Self-Insured Plans
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ALEs:
Insured Plans
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Non-ALEs:
Self-Insured Plans
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Non-ALEs:
Insured Plans
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Required to report MEC information under Section 6055.
Required to report health coverage under Section 6056.
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Required to report Section 6056 information.
Not required to report information under 6055
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Required to report MEC information under Section 6055.
Not required to report under Section 6056.
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Not required to report under Section 6055 or 6056.
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ACA Reporting Forms
Entities typically filing Forms 1094-B and 1095-B will report under Section 6055. Business filing Forms 1094-C and 1095-C for each full-time employee for any month will report under Section 6056. Those who are required to report under both Sections 6056 and 6055 will file a combined report on Form 1095-C and Form 1094-C.
Section 6055:
Form 1095-B
IRS information return that must be sent to the covered individual and filed with the IRS.
Form 1094-B
IRS transmittal Form to be filed with the IRS along with Form 1095-B
Section 6056:
Form 1095-C
IRS information return that must be sent to the covered individual and filed with the IRS.
For 1094-C
IRS transmittal Form to be filed with the IRS along with Form 1095-B.
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ACA Reporting Requirements
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Submit to the IRS:
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Recipient Copies:
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Section 6055
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Form 1094-B
Individual Copies of Form 1095-B for each person covered
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Form 1095-B
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Section 6056
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Form 1094-C
Individual Copies of Form 1095-C for each employee
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Form 1095-C
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Section 6056 &
Section 6055
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Form 1094-C
Individual Copies of Form 1095-C for each employee and individual
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Form 1095-C
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ACA Electronic Filing
By law, any Applicable Large Employers or Third Party Administrators fling more than 250 forms must file Affordable Care Act information returns electronically. If your business files less 250 forms, you can paper file, although the IRS highly encourages e-filing. Keep in mind that the Affordable Care Act reporting deadline for furnishing Form 1095-C to recipients is March 2nd, less than two weeks away.
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