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September 1, 2015

ACA Reporting

The clock continues to tick and the reporting requirements associated with the Affordable Care Act (ACA) are just around the corner.  You may be ahead of the curve and already have your solutions in place.  Or, you may still be asking questions and trying to gain clarity.  Questions we have heard from customers include:

I am confused as to whether my company should be filling out the 1094b and 1095b or C’s…

•    The answer to this question rests in whether you are a large or small group based on your applicable large employer status.

(Refer to the Ag Employers Guide to Health Care Reform or http://www.wgat.com/news/2015-employer-mandate-explained for more on this topic)

Are we considered a self-insured employer?

•    The plans available under WGAT are self-insured plans.  Under ACA reporting, the plan sponsor of a self-insured plan is responsible for the reporting.  But there is an exception for MEWAs (yes, WGAT plans are under a MEWA).  Employers with self-insured plans from a MEWA are responsible for the reporting.

If not, then do I just not file anything for 2015?

•    Not filing for 2015 will likely result in potential for penalties unless you qualify for a special exemption.

I’ve heard that the insurance carrier will do the 1094b and 1095b—does this mean I’m off the hook?

•    For employers that qualify as small groups and are with fully insured plans, the carriers will be providing the employees with the 1095b forms and filing copies of these with the 1094b to the IRS.

•    WGAT will be providing small group enrolled employees with these forms and filing to the IRS (unless you opt out).  A mailing with more details will be coming out in the near term.

Three dates to keep in mind with respect to ACA reporting:

•    Forms due to the employees (1095b or 1095c) are due on the last day of January.

•    Filing paper forms with the IRS (this is the 1094 with copies of 1095s issued) is due by the last day of February.

•    Filing electronic submissions is due by the last day of March. (Entities filing more than 250 forms MUST file electronically.)

Not to confuse matters, but recent IRS documents state:

•    “You will meet the requirement to file if the form is properly addressed and mailed on or before the due date.  If the regular due date falls on a Saturday, Sunday, or legal holiday, file by the next business day.  A business day is any day that isn’t a Saturday, Sunday, or legal holiday.”

Earlier this month, the IRS made an announcement that contained revised draft instructions and revised forms along with instruction for the application of a 30-day extension to the filing deadlines.

For more information, see IRS publications:

•    Instructions for Forms 1094-B and 1095-B (2015)

•    http://www.irs.gov/pub/irs-dft/i109495b–dft.pdf

•    Instructions for Forms 1094-C and 1095-C (2015)

•    http://www.irs.gov/pub/irs-dft/i109495c–dft.pdf

Collectively, your tax professionals, Human Resources staff and benefit providers will be needed to facilitate your reporting needs.  WGIS remains committed to helping our members anticipate and prepare for this upcoming requirement.  For more information on this topic, contact your account manager with WGIS or call 800-333-4WGA.