Beginning next year, you must provide all full-time employees with Form 1095-C to report offers of health insurance. The IRS reiterates that all large employers (i.e., those with at least 50 full-time employees, including full-time equivalent employees) must provide full-time employees with forms, even employees who turn down offers of coverage, and file those forms by the W-2 deadlines. To help you jump-start your Form 1095-C reporting, the IRS has released draft versions of Forms 1095-C and 1094-C.
Good news: Not much has changed on Form 1095-C.
What’s new. The only change to Form 1095-C is the addition of a new field, Plan Start Month, in Part II. Completing this field is optional for 2015 forms. The draft also includes a continuation sheet self-insured employers can use to report more than six individuals. For 2016 (i.e., forms filed in 2017) and later years, there will be two new codes for Line 14 to indicate conditional offers to spouses. Get a look at the draft forms here, and type 1095-C in the find box.
Electronic filing. If you file at least 250 forms, you must file electronically. You may e-file your own forms, in which case you are an issuer, or you may allow a third party, such as your, who is a transmitter, to file on your behalf.
Tip: Now is the time to confirm your filing arrangements with your third party.
Even better: The IRS says that third parties don’t have to complete Form 8655 before filing on your behalf.
The IRS has created a new electronic system—the Affordable Care Act Information Return System, or AIR for short. AIR accepts submissions in the XML format only. Prior to filing, you must obtain login credentials by registering at the IRS’ online e-Services Registration portal, and then login within 28 days to confirm registration and activate your IRS user account. Register here.
You will also need to apply for an ACA Information Return Transmitter Control Code (TCC).
Tip: Applying for your TCC soon will leave you ample time to submit required test files. The IRS has released two draft publications for software developers and employers:
Pub. 5164, Test Package for Electronic Filers
New FAQs. The latest FAQs from the IRS clarify that large employers with no full-time employees for any month don’t have to file Forms 1095-C/
1094-C. The IRS also clarified that you may provide Form 1095-C to a departing employee within 30 days of a request.
Contrast: You must provide an early W-2 to a departing employee within 30 days of a request.