On March 10, 2014, the Internal Revenue Service (IRS) published final Treasury regulations (Employer mandate - Section 4980H) for two separate information reporting requirements added to the Internal Revenue Code by the Patient Protection and Affordable Care Act of 2010, as amended (PPACA or ACA). Other sections of the code that come into play throughout the administration of IRC ₴6056 and IRC ₴6055 that specifically addressed the employer reporting. The act also included the requirements for employees. This section was referred to as the Individual mandate – IRC section 5000A and Premium Tax Credits IRC section 36B.
July 24, 2014 the IRS published draft forms to address reporting. The IRS finalized these forms on February 4, 2015. Final versions of forms 1094-C and 1095-C with instructions were published on the IRS Forms and Publications website for 2014. Forms and Instructions for 2015 are still to be published by the IRS along with the electronic filing requirements for 2015.
IRC₴ 6056 Applicable Large Employers (ALE) with at least 50 full-time employees (& FTE) are required to report to the IRS information about minimal essential healthcare coverage, if any, they offered to full-time employees (30 hours or more) in order to administer the employer share responsibility provisions of section 4980H. These employers must also furnish form 1095-C statements (Parts I & III) to employees offered benefit coverage for use when filing their 2015 Form 1040. Employers also file a copy of these forms 1095-C with the IRS.
IRC₴ 6055 addresses health insurance insurers, self-insured employers and others that provide minimal essential healthcare coverage to individuals. Self-insured benefit customers also follow these provisions. These Employers also file forms 1095-C but additionally provide information in Part III of the form on who is covered under the plan and period(s) of coverage. These employers must also furnish form 1095-C statements to employees offered benefit coverage for use when filing their 2015 Form 1040. Employers also file a copy of these forms 1095-C with the IRS.
The Benefit Offer reporting is done annually, following calendar year cycle just like Payroll does for W2 Processing. ACA has therefore, created a new Benefit Year End process that will be the responsibility of your Benefits team. Reporting of the Benefit Offer 1095-C forms was optional for Tax Year (TY) 2014. Infor did not support this reporting.
Speak with your legal counsel to determine which provision(s) apply to your situation. Infor’s software provides functionality to support these regulations but in no way should Infor’s software or information published about our software updates to support compliance be construed as tax advice.
Spotlight on Infor Solutions
Learn how Infor is enhancing its systems to prepare for ACA compliance reporting for Benefits Year End 2015.
View the Statement of Direction
What’s New for the Affordable Care Act in Infor HCM
Learn what Infor is doing to help you prepare for and manage Affordable Care Act requirements. Review the ACA requirements already in place as well as the mandates for 2015, and hear how Infor is enhancing its systems to prepare for upcoming compliance deadlines.Click to view webinar
Q&A for Offers of Employer Health Coverage (Section 6056)Click to view
Q&A for Offers made by Self-Insured Employers (Section 6055)Click to view
Over the next few months Infor communicating more about releasing ACA components to support 2015 Year End Reporting for Benefit offers. Check back here frequently for updates.
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