Affordable Care Act
Continued from Page 19
the coverage maintenance period is Feb. 9, 2014, through the
end of the last day of the 2014 plan policy year. For example, if
an employer has a fiscal year plan that renews May 1, 2014, the
coverage maintenance period is Feb. 9, 2014–April 30, 2015.
Section 6056 returns must be filed with the IRS annually,
no later than Feb. 28 (March 31 if filing electronically) of the
year immediately following the calendar year to which it refers.
Due to 2014 employer mandate transition relief, the first
returns are required to be filed for the 2015 calendar year and
must be filed no later than March 1, 2016, (Feb. 28, 2016, is a
Sunday) or March 31, 2016, if filing electronically.
Employee Statements must be furnished annually to all
full-time employees on or before Jan. 31 of the year immediately following the calendar year to which the employee
statements refer. The first Section 6056 Employee Statements
must be supplied no later than Feb. 1, 2016 (Jan. 31, 2016, is a
Sunday).
Employers that qualify for the additional one-year delay
must certify on their Section 6056 Form 1094-C Employer
Reporting that they meet the requirements for the additional
one-year delay from 2015 to 2016. Even if the ALE qualifies
for the one-year delay and is not required to comply with the
employer shared responsibility provision of the ACA in 2015, the
employer reporting is still required to be completed for the year
2015.
Penalties
An applicable large employer that fails to comply with the
filing and statement furnishing requirements of Section 6056
may be subject to the general reporting penalties for failure to
file a correct information return and failure to furnish correct
payee statements. Penalties may be waived if the failure is due
to reasonable cause and not willful neglect.
What now?
2014 Issue 4 |
the
SCORE
20
The reporting requirements are complex and add even
more paperwork and confusion to an already burdensome
process. Employers should begin to review the draft forms
1094-C and 1095-C as well as the recently released instructions
to begin to understand the type of data and information you
will need to report for the year 2015. The reporting is not due
until 2016 but you cannot and should not wait until 2016 to
understand the information that is required to be included. You
should contact your accountant, CPA firm or payroll processing
partner to ask what resources may be available to you to assist
in complying with the Section 6056 reporting.
The employer reporting requirements are one provision of
the Affordable Care Act that impact you, the employer. Are you
fully educated on your complete requirements and know what
you should be doing now to comply in 2015 or 2016? Have you
researched plan designs and run the numbers to understand
how to minimize your company costs to comply with ACA?
Have you considered a“skinny”or Minimum Essential Coverage
ACA
Re p o rt
i ng
Re qu i re
me n ts
(MEC) plan? If
not, I urge you to
contact FBS Member Services to
learn more about the Health+ program and
the exciting and unique new plan designs that have
been developed specifically for YOU and YOUR employees! You
may reach a Health+ representative by calling 678-797-5160,
emailing [email protected] or visiting
fbs.yourhealthplus.org.
The statements and information presented in this article are
intended for general information purposes only; they are not intended
to serve as professional advice and should not be construed as such.
While the information provided by Health+ is intended to be up to
date and correct, we make no representations or warranties of any
kind, express or implied, about the completeness, accuracy, reliability,
suitability or availability with respect to the article for any purpose.
Any reliance you place on such information is therefore strictly at
your own risk.
The information presented is included with the understanding
and agreement that Health+ is not engaged in rendering legal or
other professional services by presenting this material. Additional
legal, accounting and/or other advice should be sought if further
assistance is required.
Christy Williams is the FBS executive director and the Health+
program manager.