Eight Things Applicable Large Employers (ALEs) Should Know about Information Reporting and Health Coverage Offers

The Affordable Care Act (ACA) requires ALEs to file information reporting returns with the IRS and employees.  ALEs are generally those employers with 50 or more full-time (FT) employees, including FT equivalent employees in the preceding calendar year.

The substantial majority of employers are not ALEs, and are not subject to this health care tax provision.  However, those who are,  must use  Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and  Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to report this information about offers of health coverage and enrollment in health coverage for their employees.

The following are eight items ALEs must know about the information returns they are required to file at the beginning of 2016.

1- Form 1095-C is used to report information about each employee who was a FT employee of an ALE member for any month of the calendar year.

2. Form 1094-C must be used to report to the IRS summary information for each employer, and to transmit Forms 1095-C to the IRS. 

3. ALEs file a separate Form 1095-C for each of its FT employees, and a transmittal on Form 1094-C for all of the returns filed for a given calendar year.

4. Employers that offer employer-sponsored self-insured coverage use Form 1095-C to report information to the IRS and to employees about individuals who have minimum essential coverage under the employer health plan.

5. The information reported on Form 1094-C and Form 1095-C is used in determining whether an employer owes a payment under the employer shared responsibility provisions.

6. Form 1095-C is used by the IRS and the employee in determining their eligibility of the employee for the premium tax credit.

7. An ALE may satisfy this requirement by filing a substitute form, but the substitute form must include all of the information required on Form 1094-C and Form 1095-C and satisfy all the IRS’s requirements.

8. Forms 1094-C and 1095-C, or a substitute forms are required to be filed regardless of whether the ALE member offers coverage, or the employee enrolls in any coverage offered.