With the end of the year approaching, it is important to be aware of reporting requirements your organization may be subject to under the IRS. Governmental and tax-exempt entities that are considered applicable large employers are subject to information reporting requirements under the Affordable Care Act. An applicable large employer for 2015 is an entity that had at least 50 full-time employees, including full-time equivalent employees, during 2014. You will need to determine the number of full-time and full-time equivalent employees for each month during the calendar year and then divide by 12 to see if you meet the criteria for an applicable large employer.
- Full-time employee – For a calendar month, an individual employed on average at least 30 hours of service per week, or 130 hours of service per month.
- Full-time equivalent employee – Calculated in the following two steps:
- Combine the number of service hours of all non-full-time employees for the month up to 120 hours of service per employee.
- Divide the total by 120. The result is the number of full-time equivalent employees for the month.
If you meet the criteria for an applicable large employer in 2015, you are required to provide statements (Form 1095-C) to employees who were considered full-time for at least one month of the year regarding the health coverage you offered or to show that you did not offer health coverage. These forms must be provided to employees by February 1, 2016.
Applicable large employers must also file the following information returns to the IRS:
- Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. This form is used to report summary information for the employer and to transmit Forms 1095-C to the IRS.
- Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. This form is used to report required information to employees and to report information about employees to the IRS.
These forms are due to the IRS by February 29, 2016, if paper filed, or March 31, 2016, if electronically filed.