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  • IRS Reporting Requirements Update

    January 14, 2016

    IRS Extension of 1095 Form Filing Requirements

    In late December, the IRS extended due dates for both 1095-B and 1095-C statements to be delivered to individuals. It has also extended the due dates for when applicable large employers (ALEs) and insurance carriers need to file the corresponding 1094-B and 1094-C forms. 

    • The new deadline for providing 1095-C statements to employees is March 31, 2016.
    • The new deadline for filing the 1094-C with the IRS is May 31, 2016, if filing manually; June 30, 2016, if filing electronically

    How PacificSource will help

    The extension has not changed our plan or timeline for providing our large, self-funded employer groups with the data we have regarding coverage. Our 1095-C Data Assistance Report (an Excel spreadsheet) will include data you will need for Form 1095-C, Part III: covered individual names (employee and dependents), Social Security numbers, dates of birth, and months of coverage. For ease of data correlation, the report will also include subscriber and dependent indicators, employee addresses, account numbers, employer name, and employer TIN.

    Final 1095-C data assistance reports were emailed via a secure email portal the second week of January. If you haven’t already received your report, please contact your Membership Representative.

    Our ACA Reporting Requirements Guide outlines the purpose of the forms and who is responsible for each. It has been updated to reflect the extension dates. You’ll find the flier on our website at PacificSource.com/aca-reporting-requirements-guide.pdf.

    For more information about the requirements, visit the IRS website’s ACA Information Center for Applicable Large Employers (ALEs).

    Please consult with your own legal and tax advisors for advice specific to your business. While every attempt has been made to ensure the accuracy of this information as of the publication date, federal and state rules and interpretations of the ACA continue to evolve, and every employer’s circumstances are unique.

    What this means for your employees

    The 1095-C is required for filing their 2015 federal tax return and proves to the IRS that they have had minimum essential healthcare coverage issued by PacificSource for the months indicated. The form tells the IRS they are not subject to the individual shared responsibility penalty.

    The deadline for individuals to file their 2015 tax return (April 18, 2016) has not changed. Individuals do not have to wait to receive Form 1095-B or 1095-C before filing their tax return. They do not need to send the forms to the IRS; they should keep them with their other tax records.

    The IRS website has more information for individuals, including a detailed FAQ. If your employees have tax-related questions, we recommend they talk with a tax advisor or IRS representative.

    The W-2 Reporting Requirement

    The ACA requires employers who provide group health insurance coverage to their employees to report the cost of that coverage (both the employer and employee contribution) on each employee’s W-2. The reporting requirement does not affect the tax status of the benefits, but was designed to assist in collecting the data necessary to administer various provisions of the law.

    Who is affected by the requirement:

    • Employers who filed more than 250 W-2s for the 2014 tax year are required to report beginning with 2015 W-2s (distributed in early 2016).
    • In future years, employers who filed more than 250 W-2s for the previous tax year are required to meet this requirement.
    • At this time, there is no deadline in place for employers with fewer than 250 W-2s in the preceding year to meet this requirement. Further guidance from the IRS is expected.

    Note: The implementation timeframe is based on the number of W-2s filed for 2015, not the number of people you employ. So if you have fewer than 250 employees, you could still be required to begin reporting this year due to employee turnover.

    If you have more than 220 eligible employees, a spreadsheet is available through your Membership Service Representative [Ed. correction 1/18/16] to help you calculate the amounts to enter on your employees’ W-2s. If you have questions, please contact your Membership Service Representative.

     

    Questions?

    We’re happy to help. Please contact us at (800) 422-7038 or psacustomerservice@pacificsource.com.