Pub. 6 2016-2017 Issue 2

8 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S FEATURE ARTICLE ROBERT CONNER, CPA BKD, LLP ACA Information Reporting – Employer Notices Are Coming June 30, 2016, was a reporting milestone for the Affordable Care Act (ACA): Certain large employers were required to electroni- cally file their 2015 IRS Forms 1094-C, Trans- mittal of Employer-ProvidedHealth Insurance Offer and Coverage Information Returns, and 1095-C, Employer-ProvidedHealth Insurance Offer and Coverage Insurance. For employers eligible to file the paper forms, the deadline for IRS submission was May 31, 2016. Note: Because many employers expe- rienced technical difficulties and could not electronically transmit their 2015 forms by the deadline, the IRS recently acknowledged that they are still accepting the forms. The IRS has further indicated that 2015 late filing penalties for the 1094/1095 Forms will not generally be assessed if the employer has made legitimate efforts to electronically file their forms, and completes the filing as soon as possible. Paper filers who missed the May 31, 2016 deadline should also complete the filing of their paper returns as soon as possible. This reporting requirement affects all self-insured employers and any employer—or controlled group of employers—with an average of 50 or more full-time employees, including full-time equivalent employees, during the prior year. As explained in a previously published BKD article, these reports are essential for the IRS to determine whether: 1. An individual maintains minimum essential coverage for purposes of the individual health insurance mandate 2. An individual qualifies for a premium tax credit from exchange plans 3. An employer is subject to a shared responsibility penalty for failing to offer full-time employees affordable minimumessential coverage providing minimum value Note: Shared responsibility penalties generally only apply if a large employer fails to offer full-time employees affordable health coverage, and a full-time employee receives a premium tax credit or cost-share subsidy when purchasing individual health coverage on an exchange. Now’s the time to start planning for 2016 information reporting due in 2017. Pleasemon- itor BKD’s ACA IRS Reporting Resource Center for updates on the filing requirements and ways BKD can help your organization remain compliant with the reporting requirements. Note: The due dates for 2016 forms filed in 2017 are January 31, 2017, for furnishing These notices are not junk mail and should be taken seriously; they’re intended to notify employers they may be subject to an employer- shared responsibility penalty.