New IRS Employer Reporting Requirements Under ACA

AAFCPAs reminds clients that, pursuant to the Affordable Care Act (ACA), the employer information reporting provision for offers of minimum essential coverage, which applies only to applicable large employers, is now in effect.
Do you qualify as an ALE?
An applicable large employer (ALE) is, for a particular calendar year, any single employer, or group of employers treated as an Aggregated ALE Group, that employed an average of at least 50 full-time employees (including full-time equivalent employees “FTE”) on business days during the preceding calendar year. For purposes of determining your average number of employees, disregard an employee for any month in which the employee has coverage under a plan.  For 2015, you may determine your status as an ALE by reference to a period of at least six consecutive months during 2014 rather than the entire 2014 calendar year. If you are a new employer (that is, you were not in existence on any business day in the prior calendar year), you are an ALE for the current calendar year if you reasonably expects to employ, and actually do employ, an average of at least 50 full-time employees (including FTEs) on business days during the current calendar year.
What is required?
If you qualify as an ALE, you are required to file Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.  Form 1094-C is used to report to the IRS summary information and to transmit Forms 1095-C to the IRS, which must be done by Feb. 29 2016 (because Feb. 28, 2016 is a Sunday).  Form 1095-C is used to report information about each full-time employee, and is the form that is furnished to full-time employees, due by Feb. 1, 2016 (because Jan 31, 2016 is a Sunday), or March 31 if filed electronically.
If you are an ALE that sponsors a self-insured group health plan for your employees, you also must report information about employees and their dependents who enroll in the coverage, whether or not the employee is a full-time employee.
For more detailed information, you may visit  If you have any question about how the new ACA provisions impact you directly, how to determine your employees’ full time status or how to calculate the average FTE, please contact your AAFCPA partner, or Rich Weiner, CPA, Partner at 774.512.4078,

About the Author

Rich has over 30 years of broad tax experience with a specialty in tax planning and consulting for private and publicly-held businesses. Rich has specific expertise in the Software, Bio-Technology, Medical Device, Life Science, Manufacturing, Retail, Professional Service and Publishing industries, as well as U.S. aspects of international taxation. He works extensively with European companies expanding into the U.S. market. Additional areas of focus include companies and stockholders in transition, including structuring of and planning for Mergers & Acquisitions, planning for changes in ownership and management, and adoption of tax methodologies with a view toward the long term. He is well known in his field and is a frequent speaker on a variety of tax related topics.

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