Healthcare Reporting Update

The IRS has issued a notice (Notice 2016-4) that extends the time employers and insurers have to file Forms 1095-B and 1095-C. The due date for furnishing the forms to individuals is now 3/31/16 instead of the original filing date of 2/1/16. The due date for filing the forms with the IRS has now been extended to 5/31/16, or 6/30/16 if filing electronically. With this additional time provided by the IRS, any additional extensions on due dates will not be granted.

Even with these revised due dates the IRS is encouraging employers and insurers to provide these forms to the employees and IRS as soon as employers have them available.

Background Information. 

As a reminder, if you are not a large applicable employer (ALE) for health insurance purposes and if you are not a self-insured employer, you do not have any reporting requirements for 2015. An ALE is an employer with 50 full-time equivalent employees during the prior calendar year. There are transition relief provisions for determining an applicable large employer for 2015 and offering affordable insurance, but for the reporting requirements, the number of full-time equivalent employees is still 50.

Form 1095-B form is used by insurers to report to individuals and the IRS information regarding insurance coverage and information for the individual insurance mandate/individual shared responsibility payment. Generally, this means that insurance companies will be filing this form. However, if you are an employer that is self-insured, you will be responsible for providing this form to your employees, regardless of the size of your company. If you are an employer that is self-insured, but you are also an ALE, you will not need to file Form 1095-B, but will instead fill out section III of Form 1095-C.

Form 1095-C. All ALE’s will be required to file Form 1095-C. An ALE will file a form for each full-time employee. Even if an employee was only full-time for a month, a form will need to be prepared for them (there are some exceptions). If the ALE has a self-insured plan, then a form will need to be prepared for each employee that is enrolled in the plan, regardless of whether that person is full-time or not.

If you would like additional information or to discuss the topics mentioned, please contact Marie Jett, CPA at 317-260-4472 or mjett@greenwaltcpas.com.