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New ACA Reporting Requirements for Your Business

The IRS mandated new reporting requirements to enforce the Affordable Care Act (ACA) that affect your business and its healthcare accounting. These new forms will enable the IRS to verify that taxpayers held insurance with minimum essential coverage and were enrolled for all 12 months. Reporting is early in the year: you must submit your forms (Forms 1094-B and 1095-B) for 2015 at the beginning of 2016.

Both health insurance issuers or carriers and plan sponsors must file an information return reporting coverage. Small employers (those with fewer than 50 full-time employees) must file as well.

Those companies offering self-insured plans and anyone providing minimum essential health insurance coverage to individuals must report such coverage to the IRS.

Generally, the health insurance issuer or carrier—not the employer—is required to file Forms 1094-B and 1095-B for fully insured group health plans. However, plan sponsors of self-insured group health plan coverage need to report coverage for their employees and any covered dependents.

Entities that qualify as plan sponsors of self-insured group health plans include:

  1. The employer, for a self-insured group health plan or arrangement established or maintained by a single employer.
  2. Each participating employer, for a plan or arrangement established or maintained by more than one employer (other than a multiemployer plan or a multiple employer welfare arrangement (MEWA), which we discuss in items c. and e., respectively).
  3. The association, committee, joint board of trustees, or other group of representatives who establish or maintain the plan for a self-insured group health plan or arrangement that’s a multiemployer plan (e.g., a union plan).
  4. The employee organization for a self-insured group health plan or arrangement maintained solely by an employee organization.
  5. Each participating employer (with respect to its employees) for a self-insured group health plan or arrangement maintained by a MEWA.

If the plan sponsor is not identified above, the person designated by the plan terms as the plan sponsor or plan administrator qualifies as the sponsor. If no person is designated as the administrator and a plan sponsor can’t be identified, each entity that maintains the plan or arrangement also qualifies.

If the reporting entity needs to file more than 250 Forms 1094-B and 1095-B, the IRS requires filing them electronically by March 31. The deadline for paper-filed forms is February 28.

Failure to report will result in penalties from $30-100 per form, plus another $30-100 per form for failing to furnish forms to employees.

If you need help reporting your business correctly or understanding these new requirements, contact the tax accountant team at Patrick & Robinson CPAs: or 904-396-5400.

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