Employers breathed a sigh of relief last year when the IRS extended filing deadlines for Affordable Care Act (ACA) information reporting. However, it doesn’t appear employers will be so lucky this year. This may prove challenging for employers who must file 1095-Cs by January 31. If you’re printing forms, you’ll want to ensure they go to the printer by January 20 to give you plenty of time. Here are the deadlines:
|ACA Information Reporting Forms||2016 Tax Year Deadlines (forms filed in 2017)|
|Forms 1095-B and 1095-C due to employees (to be postmarked if mailed or sent by email if applicable conditions met)||January 31, 2017|
|Forms 1094-B, 1095-B, 1094-C and 1095-C due to IRS if filing on paper||February 28, 2017|
|Forms 1094-B,1095-B, 1095-C due to IRS if filing electronically*||March 31, 2017|
* Employers filing 250+ returns must file electronically
“It can be a bit overwhelming,” says Brian Pfeifer, Deluxe Payroll’s Chief Operating Officer. “But if you put in the work ahead of time and don’t wait until the last minute you should be in good shape.”
Of all the new ACA reporting requirements, those under Section 6055 and 6056 are among the most difficult. Employers with a self-insured health plan with minimum essential coverage must
distribute to enrolled employees and file Form 1095-B. Applicable employers with 50+ full-time employees/equivalents must distribute to enrolled employees and file Form 1095-C. If these employers offer self-insured health plans they may use Form 1095-C in lieu of Form 1095-B. For IRS filings, Forms 1095-B and 1095-C are accompanied by transmittal Forms 1094-B and 1094-C.
Say Goodbye to Transition Relief
Starting this year, organizations with 50+ employees/equivalents must insure 95% of full-time employees to avoid penalties. Keep in mind that it’s not 95% per year, it’s 95% per month. The IRS will ask for payroll/benefits data to ensure accuracy.
Keep an Eye Out for Exchange Subsidy Notices
Large employers should be on the lookout for notices alleging that a full-time employee received subsidized coverage because the employer didn’t provide coverage. Appeals must be submitted within 90 days of receiving the notice. Having a system that tracks benefits will come in handy in such cases.
HR, the CFO/controller and the accountant/tax adviser should sit down to see that they are in agreement, especially in regard to indicator codes. Involving your payroll vendor will greatly simplify this process.
Revisit Compliance Tactics
The big question here is whether you are going to do this yourself or outsource it to a third-party vendor. What did you do last year? Did it work? If you used a vendor, was it a good experience or should you explore other options?
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