Affordable Care Act IRS Reporting Guide

Fully Insured Employers

2017 will be the third year of the Affordable Care Act (ACA)

reporting. This reporting supports the monitoring of individual

and employer health insurance mandates. Similar to last year,

the reporting requirement will affect any employer, or controlled

group of employers, with 50 or more full-time employees on

average, including full-time equivalent employees, during the

prior year. The 2017 ACA forms will have a filing deadline of

March 2, 2018, to employees and February 28 to the IRS

(April 2 if filing electronically). Significant penalties may be

assessed for noncompliance.

How will you handle reporting to the IRS?

Fully insured employers affected by this filing requirement must notify the IRS of two things:

Whether they offered minimum essential health coverage to full-time employees and their dependents and, if so, for what months1Whether the health coverage offering was affordable2

UPDATE: IRS Notice 2018-06 provides a 30-day extension for providing 1095 forms to individuals. The due date has moved from January 31, 2018 to March 2, 2018.

Your ACA-Mandated IRS Reporting Responsibilities

If your average number of full-time employees and equivalents

for the prior year is less than 50, you have no employee reporting

obligations. However, if you have 50 or more full-time employees

and equivalents, you must furnish:

Form 1095-C to

all employees who

worked on a full-time

basis for at least one

month during 2017

Form 1094-C

(transmittal) and Forms

1095-C to the IRS

What are the IRS filing deadlines?

» Employees must receive hard copies of forms unless employer acquires affirmative consent for electronic submission (consent for electronic W-2 distribution does not count)

» IRS electronic filing is mandatory if submitting 250 or more 1095s

» 30-day extension granted for IRS transmittal by filing Form 8809

Forms must be furnished to employees by March 2, 2018

Forms must be transmitted to IRS by February 28, 2018, if paper filing, or April 2, 2018, if filing electronically

Failure or late filing of forms could subject employer to a penalty of $260 per form

What should you do now to prepare?

Print the blank forms and instructions you need to file with the IRS—for your reference. Learn the information you need to start tracking each month.

Know your sources of information. Is it in your payroll or benefits administration system? Is it in Excel or in a network drive?

Develop a game plan and immediately start collecting the monthly information you need to report at year-end.

Contact your BKD advisor for more information or with questions about your ACA IRS reporting requirements and how to best prepare.

BKD can help you comply with ACA IRS reporting by:

Guiding you through ACA filing based on the coverage offering and size of your workforce1Helping you compile and format necessary data frominformation systems2Importing your data into a secure, cloud-based application that allows you to validate your data prior to filing3Producing 1095 and 1094 forms, mailing 1095 forms to employees and electronically filing applicable forms with the IRS

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