In order to enforce the individual and employer mandates under the Patient Protection and Affordable Care Act (ACA), certain information returns are required to be filed with the Internal Revenue Service (IRS) regarding health coverage offered to full-time employees beginning on January 1, 2015. Because filing season is around the corner, make sure that you have taken steps to prepare.
Self-insured multiemployer plans are required to report plan coverage on Form 1095-B, Health Coverage, and its companion transmittal form, Form 1094-B, Transmittal of Health Coverage Information Returns. Similar to wage and compensation reporting (Forms W-2 and 1099), these forms are due to participants by January 31 (February 1 in 2016 since 1/31/16 is a Sunday) and need to be transmitted to the IRS by February 28 if filing on paper, or March 31 if filing electronically. All forms are due on a calendar year basis, regardless of the plan's fiscal year end. If your plan files 250 or more information returns for 2015, the transmittal to the IRS must be done electronically through the ACA Information Reports System. The “250 or more” requirement applies separately to each type of information return.
A copy of Form 1095-B is sent by the plan to each participant, to be used by each individual for reporting to the IRS about their health coverage. The form requires the plan to provide information regarding the "responsible individual" (plan participant) and each "covered individual" (the participant's spouse and/or dependents). Such information includes the individual's name, Social Security Number (SSN), and the months of coverage that were offered to each individual. If the SSN is not readily available to the plan, the date of birth may be reported instead, but solicitations for the SSN must be made within a prescribed timeframe in order to avoid penalties.
Contributing employers to your plan may need to file 1095-C, Employer-Provided Health Insurance Offer and Coverage, and its companion transmittal form, Form 1094-C, if they are considered an "applicable large employer" (averaged at least 50 full-time employees during 2015). Such employers may request proof that your plan complied with the minimum value, affordability and dependent coverage standards of ACA. There is no government form in relation to this information, and therefore, a written statement will suffice.
If your plan uses benefits administration software developed or provided by a vendor, talk to your vendor as soon as possible if you have not done so already. You will need to obtain or develop, and test, the software in time to make sure your plan has the capabilities to prepare and issue these forms by the deadlines noted above.
Lastly, make sure you have confirmed your plan participants' addresses. Your protocol for mailing paper statements may include retaining proof of mailing for individual statements, which must be sent via first class mail to the recipient's last known address, or if unknown, to the address where the individual is most likely to receive it.
By Maria C. Solis, CPA, Partner, firstname.lastname@example.org