Affordable Care Act Reporting Requirements
The Affordable Care Act (ACA) imposes reporting requirements on employers and plan sponsors that will assist the Internal Revenue Service in determining compliance with two ACA mandates:
- The Employer Mandate - the requirement for large employers to offer affordable health care coverage of minimum value to their full-time employees (Forms 1094-C and 1095-C)
- The Individual Mandate - the requirement for individuals including their dependents to obtain minimum essential health care coverage (Forms 1094-B and 1095-B)
Failure to comply with the employer mandate may result in the employer being subject to additional IRS penalties.
Health Reimbursement Arrangements
The reporting requirements for small and large employers that sponsor a health reimbursement arrangement (HRA) and participate in a health plan sponsored by the Medical Trust have been updated by the IRS.
- Small employers may also need to prepare and file separate Forms 1094-B and 1095-B
- Large employers may also need to complete Part III of Form 1095-C
What does this mean to my organization or diocese?
If your organization or another organization in your diocese is a “large employer” (as defined below), you or that other organization will be responsible for filing the employer mandate tax forms (Forms 1094-C and 1095-C). The Medical Trust will not complete these forms. See More Information about Reporting for details.
- Large employers that do not sponsor an HRA will not need to complete Part III of Form 1095-C because that information will be included in Form 1095-B that either the Medical Trust or the insurer will prepare
- Large employers that sponsor an HRA and participate in the health plans sponsored by the Medical Trust may also be required to complete Part III of Form 1095-C for their employees
If your organization or another organization in your diocese is not a large employer (as defined below), you or the other organization are considered a small employer. If you do not sponsor an HRA, you will not be required to take any action as a result of these reporting requirements.
- Small employers that sponsor an HRA and participate in the health plans sponsored by the Medical Trust may be required to prepare and file separate Form 1094-B and 1095-B for their employees
The IRS tax forms (Forms 1094-B / 1095-B) required for the individual mandate must be provided to employees covered by a healthcare plan for both large and small employers. These forms will be filed by either the Medical Trust or, in the case of fully insured medical plans, the insurance carrier. Therefore, you and organizations within your group that participate in the Medical Trust plans are not responsible for filing the individual mandate tax forms.
- Note, however, that small employers that sponsor an HRA may be required to prepare and file separate Forms 1094-B and 1095-B for their employees. If you sponsor an HRA, please review Notice 2015-68 and consult your tax advisor.