Pay or Play Information Reporting: 2015 Checklist for Completing IRS Forms 1094-C & 1095-C

This checklist is designed to help large employers - generally those with 50 or more full-time employees, including full-time equivalents (FTEs) - report information under Internal Revenue Code section 6056 about their compliance with the Affordable Care Act's (ACA) employer shared responsibility ("pay or play") provisions. These large employers are required to report for the first time in early 2016 for calendar year 2015.

Please Note: This list is for general reference purposes only and is not all-inclusive. If you have any questions regarding your responsibilities, please contact a knowledgeable employment law attorney or benefits advisor.

1. Determine "Large Employer" Status.
  • Only large employers subject to "pay or play" are required to report under section 6056-including those that qualified for 2015 transition relief from "pay or play" penalties. A large employer is one that employed an average of at least 50 full-time employees (including full-time equivalents or "FTEs") on business days during the preceding calendar year. 
2. Begin Monthly Information Tracking: Full-Time Employees & Coverage Offered.
  • Identify full-time employees for each month in 2015. o Full-Time Employee: An employee is full-time for a calendar month if he or she averages at least 30 hours of service per week (or 130 hours per month). 
3. Select Reporting Method.
  • Under the general method of reporting, a large employer generally must file: 
    • A separate Form 1095-C (employee statement) for each of its full-time employees; and 
    • A Form 1094-C (transmittal) for all of the employee statements filed for a given calendar year.
  • The alternative reporting methods identify specific groups of employees for whom simplified alternative reporting would provide sufficient information. If a large employer cannot use the alternative reporting methods for certain employees, the employer must use the general method for those employees.
    • Qualifying Offer Method
    • 98% Offer Method
4. Begin Compiling Required Reporting Information.
5. Review the IRS Forms and Instructions for Specific Reporting Requirements.
  • Forms 1094-C and 1095-C, along with instructions, are available for large employers (including large employers that sponsor self-insured group health plans that are subject to both reporting provisions) to prepare for compliance.
6. Determine Whether to Hire a Third Party to Fulfill Reporting Responsibilities.
  • Large employers are permitted to use third parties to facilitate filing returns and furnishing employee statements to comply with reporting requirements. However, this does not transfer the large employer's potential "pay or play" liability, nor does it transfer the potential liability for the failure to report and furnish statements.
7. If Furnishing Employee Statements Electronically, Satisfy Certain Requirements.
  1. Affirmative Consent
  2. Required Disclosures
  3. Format
  4. Notice
  5. Access Period
8. Comply With Information Reporting Deadlines for Calendar Year 2015.
  • First transmittal forms and employee statements must be filed with the IRS no later than February 29, 2016, or March 31, 2016 if filed electronically. (Regulations under Internal Revenue Code section 6081 address extensions of time to file.)
  • First employee statements must be furnished to all full-time employees no later than February 1, 2016 (January 31, 2016 being a Sunday).

For more in depth detail regarding the Employer Checklist, click here.

Call The Lynn Company at (661)-873-2200 for more information on Completing IRS Forms 1094-C & 1095-C
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