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It may feel like you just finished all your 1094 and 1095 reporting as required by the ACA, but the reality is that reporting is an annual requirement, and it’s time to start thinking about your 2016 reports.
As was the case in 2015, the carrier will complete Forms 1094-B and 1095-B for fully insured small group plans. Small groups that sponsor a self-funded group health plan will need to complete these forms as well. Small group, fully insured plans with a self-funded HRA will need to complete Forms 1094-B and 1095-B for the HRA.
All Applicable Large Employers (ALEs) will need to complete Forms 1094-C and 1095-C; this is any group with 50 or more full time equivalent employees in 2015. ALEs who sponsor a fully insured plan won't need to complete Part III of Form 1095-C. ALEs who sponsor self-funded group health plans will need to complete Part III of Form 1095-C.
The reporting is done on a calendar year basis. Regardless of plan year, all ALEs will need to complete the 2016 reporting. All Form 1095s need to be provided to individuals on or before January 31 of each year (or the next business day if it falls on a weekend or Federal holiday).
Entities filing 250 or more 1095-Cs must file their returns electronically. Keep in mind when determining how many Form 1095-Cs you will have that you must issue one to anyone who was a full-time employee during the year, even if only for a month, and to anyone who was covered by your plan even if they weren’t a full-time employee. As with other transmittals of information returns, the transmittal should be filed at the same time using Form 1094-B or 1094-C. Employers with fewer than 250 returns are also encouraged to file electronically, but may opt to make the returns in paper form. The filing deadline is no later than February 28 (March 31 if filed electronically) for the previous year. The next returns will be filed for the 2016 calendar year. These will need to be filed by February 28, 2017, or March 31, 2017 if filed electronically.
Electronic reporting requires submission through the ACA AIR Program. In order to file electronically, employers will either need to rely on a service provider to submit the forms on your behalf, or need someone fluent in software development/coding in order to develop internal resources to comply with the filing requirements. Both approaches can be a lengthy process, so sufficient time should be allotted to either get established with a vendor or work on development of internal processes.
Contact your Assurance representative if you haven't yet determined your method of filing.