Affordable Care Act Employer Reporting Requirements for 2015
As part of the continued roll out of the Affordable Care Act, beginning in 2015 large employers must file Forms 1094-C and 1095-C with the IRS. A large employer is typically one with 50 or more full-time and full-time equivalent employees. The information returns are due by February 29, 2016 or March 31, 2016 if filing electronically.
- Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
- Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
Even though employers with 50 to 99 full-time employers are not subject to the employer mandate for health insurance coverage until 2016, they are still required to comply with the reporting requirements for 2015. Additional information can be found on IRS.gov.
A little known and very under-publicized change to the insurance tax laws that took place on January 1, 2014, has exposed employers to a potentially heavy excise tax if they reimburse employees for health insurance premiums vs. enrolling in group plans. This includes employee shareholders.
In a 6-3 decision that upholds a key provision of the Affordable Care Act, the Supreme Court has held that the premium tax credits under IRC Section 36B are not limited solely to taxpayers who live in states that have established a health insurance Exchange. Rather, the credits (also known as health insurance subsidies), which are designed to make health insurance affordable for taxpayers who meet certain qualifying requirements, are also available to taxpayers residing in states that participate in the federal Exchange.
The U.S. government’s Centers for Medicare and Medicaid Services (CMS) has announced that it sent incorrect data on Form 1095-A to approximately 800,000 taxpayers who purchased Federally-facilitated Marketplace health care coverage under the Affordable Care Act in 2014. Form 1095-A is the form that provides data for individuals to compute the Code Sec. 36B premium tax credit on their 2014 individual income tax returns. CMS suggests that those taxpayers not file their 2014 returns until they receive corrected Form 1095-A, but has also provided alternative procedures. For more information please visit the 
With the Affordable Care Act well into establishment, taxpayers have taken an interest in learning about how the Act affects their annual tax return. The Internal Revenue Service (IRS) understands that the abundance of information available to taxpayers online can be overwhelming. To aid taxpayers in finding accurate information on the Act as well as on health care coverage, the IRS issued Publication 5093. Publication 5093 is a simple list of