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October 2, 2018The IRS has finalized the forms and instructions that employers will use for 2018 reporting under the Affordable Care Act (ACA).
Applicable large employers (ALEs) will use the following:
Employers that self-fund a minimum essential coverage plan will use the following:
Background
Applicable large employers (ALEs), which generally are entities that employed 50 or more full-time and full-time-equivalent employees in the prior year, are required to report information about the health coverage they offer or do not offer to certain employees. To meet this reporting requirement, the ALE furnishes Form 1095-C to the employee or former employee and files copies, along with transmittal Form 1094-C, with the IRS.
Employers, regardless of size, that sponsor a self-funded (self-insured) health plan providing minimum essential coverage are required to report coverage information about enrollees. To meet this reporting requirement, the employer furnishes Form 1095-B to the primary enrollee and files copies, along with transmittal Form 1094-B, with the IRS. Self-funded employers that also are ALEs may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.
Information is reported on a calendar-year basis regardless of the employer’s health plan year or fiscal year.
2018 Forms and Instructions
The 2018 forms and instructions generally are the same as the prior year’s materials. The reporting requirements have been in place for several years now, so employers and their advisors should have little trouble working with the new materials for 2018.
Note that the new forms do include a format change for entering the names of persons enrolled in a minimum essential health coverage plan. In most cases, coverage is provided through a group insurance policy so the insurance carrier (not the employer) reports this information. If the coverage is self-funded, however, the employer is responsible for reporting the covered individuals’ names, either on Form 1095-C, Part III or Form 1095-B, Part IV. Previously, there was a single space for entering the full name, but now there are separate spaces for first name, middle initial, and last name.
Due Dates
The due date to furnish 2018 forms to individuals is January 31, 2019, while the due date to file copies with the IRS, including the appropriate transmittal form, will depend on whether the employer files electronically or by paper. Entities that provide 250 or more forms to individuals are required to file electronically with the IRS.
The due dates for 2018 reporting are:
- January 31, 2019: Deadline to furnish 2018 Form 1095-C (or 1095-B, if applicable) to employees and individuals.
- February 28, 2019: Deadline for paper filing of all 2018 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS.
- April 1, 2019: Deadline for electronic filing of all 2018 Forms 1095-C and 1095-B, along with transmittal form 1094-C or 1094-B, with the IRS. (April 1 is the first business day following the usual due date of March 31.)
Summary
Employers are encouraged to work with experienced vendors, tax advisors, and payroll administrators to review how the ACA reporting requirements apply to their situation. The required forms are important IRS documents and preparers should use the same level of care that would apply to employee W-2s.
About Kathleen A. Berger, CEBS
Kathy Berger is ThinkHR’s principal benefits consultant. She is a Certified Employee Benefits Specialist (CEBS) with over 25 years of experience working with brokers and employers. Kathy uses her extensive knowledge of ERISA, HIPAA, the ACA, and other benefits laws and regulations to assist our clients with practical information in clear language.