By now, it’s likely you’re aware that several forms of transition relief from the Affordable Care Act (ACA) that were available in 2015 have expired, and only limited relief continues to apply in 2016.
As a result, the Internal Revenue Service has removed references to 2015 transition relief from 2016 Forms 1094- and 1095-C. It’s important that employers understand how these changes affect the way they will complete 2016 forms and provide data to the IRS.
In summary:
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Transition Relief check box removed
Employers no longer will be able to select “The Qualifying Offer Method Transition Relief” box on Form 1094-C, or use codes 1I and 2I to complete Forms 1094 and 1095-C. In 2016, employers will use new codes 1J and 1K to show they offered minimum essential coverage to employees, their spouses and dependents for all 12 months of the calendar year.
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Safe harbor increases to 95 percent
Applicable large employers (ALEs) now must offer health care coverage to 95 percent of their full-time employees in order to check “yes” in Part III of Form 1094-C.
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Full-time reminder added to Form 1094-C
ALEs with 50 or more full-time or full-time-equivalent employees must follow guidelines in 2016. On Form 1094-C, the phrase “Section 4980H” was added to remind filers that the 30-hour-per-week definition of “full-time employee” applies for purposes of completing Part III of Form 1094-C.
What you can do
While these changes seem insignificant, not taking them into account when completing your ACA reporting could result in noncompliance with increasingly strict requirements. This, combined with elevated penalties and fast-approaching 2017 reporting deadlines, may have you looking for a payroll provider who can assist you with ACA compliance. If so, choose a company that can file Forms 1094/1095-B or -C on your behalf and offers ongoing monitoring and education features to help you proactively manage ACA compliance.
DISCLAIMER: The information provided in this blog is for general informational purposes only. Accordingly, Paycom and the writer of the above content do not warrant the completeness or accuracy of the above information. It does not constitute the provision of legal advice, tax advice, accounting services, or professional consulting. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal or other professional services.
