As we discussed last October in our blog about changes in the Affordable Care Act, many penalties for non-compliance for "applicable large employers" are set to rise. The good news is that certain deadlines for submitting paperwork have been extended.

Applicable Large Employers

To recap, an "applicable large employer," or ALE, is defined as an employer having at least 50 full-time employees or the equivalent. For 2015, generally only ALEs with 100 or more full-timers, or the equivalent, are subject to the shared responsibility, or "play-or-pay" provision. This requires they offer a certain level of affordable health insurance to full-time employees and their dependents at a shared cost or be at risk for penalties. In 2016, play-or-pay will begin to apply to all employers having 50 to 99 full-timers.

ALEs Filing Requirements

Under the provisions of the Affordable Care Act, all applicable large employers must file form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. They must also file the Form 1095-C, Employer-Provided Insurance Offer and Coverage.

Self-insuring employers must file form 1094-B, Transmittal of Health Coverage Information Returns. They must also file the Form 1095-B, Health Coverage.

Due Date for Forms Extended

Luckily the due date for providing these forms has been extended by the IRS. Here are the new due dates:

  • The due date for furnishing the 2015 Form 1095-B and the 2015 Form 1095-C to the insured and employees is extended from February 1, 2016, to March 31, 2016.
  • The due date for health coverage providers and employers furnishing the 2015 Form 1094-B and the 2015 Form 1094-C to the IRS is extended from February 29, 2016, to May 31, 2016 if not filing electronically.
  • The due date for health coverage providers and employers electronically filing the 2015 Form 1094-B and the 2015 Form 1094-C with the IRS is extended from March 31, 2016, to June 30, 2016.

This represents a 2 to 3 month extension on deadlines, depending on the form. But don't use this deadline as an excuse to procrastinate. As tax experts, we recommend furnishing the information to the IRS as soon as you have it available.

Get the Full Picture

There are complicated rules about which forms you need to provide to full-time employees, who qualifies as a full-time employee, and how to handle employees that exercise their own insurance options. We recommend reviewing the IRS official update to get all the details.

Still Need Help?

Though deadlines have been extended, compliance is still required, rules are complex, and heavy penalties will be enforced if you miss the deadlines. It's wise to seek professional guidance. PDM's tax experts can help advise you on the best course of action. Contact us; with our years of technical experience, advanced training, and cutting edge technology, we are your financial partner.