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2015 ACA Reporting Materials and Resources for Late Filers

IMPORTANT NOTE: If you are required to report for the 2017 calendar reporting year, it is imperative that you complete and submit information for that year prior to any late filings in order to insure a timely 2017 filing and avoid penalties. If you have received correspondence from the IRS regarding the 2015 filing year, please refer to the IRS Late File Correspondence document


To get started, follow these steps:

1. Review the 2015 Client Administration Manual for Late Filers to make sure you have made the necessary ACA determinations needed to move forward with the necessary reporting. 

PLEASE NOTE: Many of the determinations needed to comply with the ACA are detailed and specific to your Plan. Reviewing the 2015 Client Administration Manual for Late Filers and taking appropriate questions to your Benefit Advisor, Benefit Counsel, or Broker prior is highly recommended.

2. Determine Your Status under the ACA

Use the 2015 Client Administration Manual for Late Filers to help you make the following determinations:

  • Were you an Applicable Large Employer (ALE)?
  • Did your Plan offer Minimum Essential Coverage?
  • Did your Plan offer Minimum Value?
  • Was your Plan affordable?
  • Did your Plan offer coverage to your FTE’s dependents?
  • Were you a new ALE?

3. Review and complete the appropriate 2015 ACA Reporting Data File based on your Health Plan type.

If you have less than 250 reportable employees, then you will be able to file a hard copy of the Information Returns with the IRS. Once we have received your completed file, we will send you a file containing all your IRS Form 1095-Cs which you would print and file with the IRS along with your IRS Form 1094-C that you will need to complete. We will also send you a file containing all IRS Form 1095-Cs with Social Security Numbers truncated that you should print and distribute to your employees.

For mailing instructions, refer to the "IRS Reporting" section in your Client Administrative Manual. 

If you have 250 or more reportable employees, then you must electronically file information returns with the IRS. This can be done either by contracting a third party filer or by filing directly with the IRS. Please refer to the ACA Electronic Filing Requirement information sheet for further guidance. For generating the IRS Forms 1095-C for distribution to employees, please refer to the instructions under "If you have less than 250 reportable employees" section above.


TASC’s 2015 ACA WIZARD

Use our automated ACA Coding Tool to easily produce recommended code inputs. Simply answer the questions for the specific employee for the month you are producing, and the ACA Wizard will go to work and recommended code inputs for IRS Form 1095-C (lines 14, 15, and 16). Unless there is a change in the employee status, you will continue to use the same code input for following calendar months.

PLEASE REVIEW THE FOLLOWING SIX (6) ITEMS BEFORE USING THE ACA WIZARD AS THE ACA WIZARD WILL NOT PRODUCE ACCURATE CODES FOR THESE ITEMS.

1. The 2015 TASC ACA Wizard is designed for the coding associated with active Full-Time Employees. For coding other than active Full-Time Employees (e.g., Terminated Employees, Part-Time employee, COBRA-eligible individuals and Retirees), please see items 3-5 below.

2. Some entries into the ACA Wizard will be unable to produce a viable code. If you receive the error message “Could not determine the code with the criteria” or show a blank line, check your answers for consistency and/or accuracy. (i.e. an entry should not state that an employee is covered under a benefit that is not offered.) Such inconsistencies may produce erroneous codes.         

3. If an Employee terminates employment mid-month and is covered through the end of the month, you would code that individual for that month the same as any Full-Time Employee with coverage. If an Employee terminates mid-month and is not covered through the end of the month, you would code that individual for that month as 1H Offer of Coverage Code, Line 14 and 2B Safe Harbor Code, Line 16. Subsequent months in the calendar year are coded as 1H Offer of Coverage Code, Line 14 and 2A Safe Harbor Code, Line 16.

4. If you have a fully-insured health plan you must report any Part-Time Employee (due to a reduction in hours), Retiree and COBRA-eligible former/terminated Employee (enrolled or not) that was also a Full-Time Employee during any month of the reporting year (i.e., the calendar year being reported). To code for these individuals, use the Wizard to determine coding for the months they were a Full-Time Employee. For those months they were not Full-Time Employees, please refer to IRS Reporting Offers of COBRA and Post-Employment Coverage for coding instructions.

If you have an individual who was a Part-Time Employee (including due to a reduction in hours), a Retiree or a COBRA-eligible former/terminated Employee (enrolled or not) and was so for the entire reporting year, you do not need to report for that individual.

5. If you have a self-funded health plan you must report any Part-Time Employee (due to a reduction in hours), Retiree and COBRA-eligible former/terminated Employee (enrolled or not) that was also a Full-Time Employee during any time month of the reporting year (i.e., the calendar year being reported). To code for these individuals, use the Wizard to determine coding for the months they were a Full-Time Employee. For those months they were not Full-Time Employees, please refer to IRS Reporting Offers of COBRA and Post-Employment Coverage for coding instructions.

In subsequent reporting years, you must report any Part-Time Employee (due to a reduction in hours), Retiree and COBRA-eligible former/terminated Employee ONLY if such individual is actually enrolled in the health plan. That employee must be reported by coding 1G for the Offer or Coverage (line 14), no Employee Share (Line 15) and no 4980H Safe Harbor Code (Line 16). Any of these individuals who have a covered spouse and/or dependent must also be reported under PART III of the Form 1095-C. This is to satisfy the Individual Mandate Reporting requirement. 

If you generally offer coverage to Part-Time Employees (other than due to a reduction in hours), ONLY those employees covered by the health plan must be reported by coding 1G for the Offer or Coverage (line 14), no Employee Share (Line 15) and no 4980H Safe Harbor Code (Line 16). Any of these individuals who have a covered spouse and/or dependent must also be reported under PART III of the Form 1095-C. This is to satisfy the Individual Mandate Reporting requirement.

6. If you have a Multi-Employer Arrangement wherein you are required by a collective bargaining agreement or related participation agreement to make contributions for employees to a multiemployer plan that offers, to individuals who are eligible for the plan, health coverage that (a) is affordable, (b) provides minimum value, and (c) also offers health coverage to those individuals’ dependents, then code 1H for Line 14 (Offer of Coverage Code), no Employee Share for Line 15 and 2E for Line 16 (4980H Safe Harbor Code).

 

 

If you have any questions, please contact Customer Care at 1-800-422-4661 or via email at acaemployerreporting@tasconline.com. Please have your 12-digit TASC ID available when contacting us.

FSA - SECTION 125 - FLEXIBLE SPENDING ACCOUNTS | HRA - SECTION 105 - HEALTH REIMBURSEMENT ARRANGEMENTS | HSA - HEALTH SAVINGS ACCOUNTS | COBRA ADMINISTRATION | FMLA ADMINISTRATION | ERISA ADMINISTRATION | PAYROLL ADMINISTRATION