The SCORE 2014 Issue 4 2014 | Page 21

Who has to file? All applicable large employers must file annual returns with the IRS to report the health care coverage offered to fulltime employees and their dependents. An ALE is an employer that employed (aggregated with members of its controlled group) an average of at least 50 full-time employees—including full-time equivalent employees (FTEs) on business days during the preceding calendar year. Regardless of whether an ALE offered coverage, all ALEs must file a return with the IRS that reports substantial information for each employee who was a full-time employee for one or more months during the calendar year. Based upon a review of the final rules, Section 6056 returns will include the following information, at a minimum, within an Employer Transmittal Return and/or Employee Statements: ALEs are permitted to utilize a third party to facilitate filing returns and furnishing employee statements, however, ALE members are ultimately responsible for the filings. Using a third party does not transfer any potential liability for failure to report. Additionally, if you use a third party, you must report that you did so. • The name, address, and EIN of the ALE member; the name and telephone number of the contact person of the ALE member; • Certification as to whether the ALE member offered its full-time employees (and their dependents) the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan, by calendar month; • The number of full-time employees for each month during the calendar year; • The number of employee statements being submitted; and, For each full-time employee, by calendar month: • The name, address, and taxpayer identification number of each full-time employee during the calendar year, and months, if any, during which the employee was covered under an eligible employer-sponsored plan; • The months during which minimum essential coverage was available to the employee; • The employee’s share of the lowest cost monthly premium for self-only coverage providing minimum value offered to that full-time employee under an eligible employer-sponsored plan; • Whether minimum essential coverage was offered to: 1) the employee; 2) the employee and dependents; 3) the employee’s spouse, or 4) to all; • If coverage was not offered to the employee, whether the employee was 1) a new variable-hour employee, 2) in a waiting period, 3) not a full-time employee, or 4) not employed during that month; When is reporting due? It is extremely important to emphasize that ALL applicable large employers are responsible for complying with employer reporting in 2015. This includes ALEs with 50-99 full-timeequivalent employees that may qualify for the one-year delay from 2015 to 2016, announced by the U.S. Treasury in early 2014. Employers with 50-99 full-time-equivalent employees may delay their compliance with the employer shared responsibility provisions of the ACA (i.e., Employer Mandate) for one year as long as they meet requirements