Church Pension Group | More Information About Reporting

More Information About Reporting

Following is detailed information regarding the tax forms employers need to file under the Affordable Healthcare Act (ACA), and which tax forms the Medical Trust and insurers will file.

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

The Internal Revenue Code requires large employers to provide information to the IRS and their employees about whether they have offered employees minimum essential coverage that is affordable and provides minimum value.
- The information must be provided on IRS Forms 1094-C and 1095-C
- The IRS will use these tax forms to determine whether an individual qualifies for subsidized coverage through a Health Insurance Exchange (the insurance market set up in each state under the ACA to allow individuals to purchase health insurance coverage)
If you or an organization in your group is a large employer, you or that organization will be responsible for preparing and filing IRS Forms 1094-C and 1095-C. The Medical Trust will not prepare these tax forms.
- 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 the Form 1095-B that either the Medical Trust or the insurer will prepare
- Large employers that sponsor an HRA may also be required to complete Part III of Form 1095-C for participants in the HRA
The IRS has published instructions to assist in meeting this reporting obligation, and employers should review the tax forms, along with their instructions, carefully. To access these forms and instructions, click on the following links:
- Form 1094-C - for large employers to transmit Form 1095-C
- Form 1095-C - for large employers to report coverage offered to individuals under the Employer Mandate Instructions for Forms 1094-C and 1095-C

Reporting Related to the Individual Mandate (Large & Small Employers)

The Internal Revenue Code requires insurers and the sponsors of self-funded plans to disclose whether plan subscribers have obtained minimum essential coverage in compliance with the Individual Mandate.

Organizations that participate in the Medical Trust plans will not be responsible for meeting this reporting requirement
- Employers that sponsor an HRA may also be required to prepare separate Forms 1094-B and 1095-B for participants in an HRA. If you sponsor an HRA, please see Notice 2015-68and consult your tax advisor
As the designated plan sponsor of the self-funded medical plans, the Medical Trust will prepare IRS Forms 1094-B and Form 1095-B or, in the case of fully insured medical plans, the insurer will prepare these tax forms

Specifically, the Medical Trust will report for each plan subscriber and his/her covered dependents the required information to the IRS on Form 1095-B, with a transmittal form – Form 1094-B. The Medical Trust will also provide this tax form to plan subscribers. The insurance carriers for fully insured medical plans will meet this requirement for each of those plans.

The filing deadlines and the responsibility for and filing deadlines for the Individual Mandate forms are summarized below.

Employer or Third Party Action	Individual Mandate Forms	Deadline
The Medical Trust or insurer will complete the form and submit it to the Plan Subscriber or responsible individual. Small employers that sponsor an HRA may also need to complete the form and submit it to the Plan Subscriber or responsible individual.	Form 1095-B	January 31, or by the date set by the IRS if extended.
The Medical Trust or insurer will complete the form and submit it to the IRS. Small employers that sponsor an HRA may also need to complete the form and submit it to the IRS.	Form 1094-B Form 1095-B	Each year by February 28 if by paper, March 31 if electronically, or by the date set by the IRS if extended.

Employer or Third Party Action

Individual Mandate Forms

Deadline

The Medical Trust or insurer will complete the form and submit it to the Plan Subscriber or responsible individual.

Small employers that sponsor an HRA may also need to complete the form and submit it to the Plan Subscriber or responsible individual.

Form 1095-B

January 31, or by the date set by the IRS if extended.

The Medical Trust or insurer will complete the form and submit it to the IRS.

Small employers that sponsor an HRA may also need to complete the form and submit it to the IRS.

Form 1094-B

Form 1095-B

Each year by February 28 if by paper, March 31 if electronically, or by the date set by the IRS if extended.

To avoid the filing of duplicate tax forms with the IRS, it is important that you inform the organizations in your group that participate in the Medical Trust self-funded plans that we will prepare and file the Form 1095-B and provide a copy to plan participants and the IRS. Insurers will be responsible for filing and distributing Form 1095-B for their medical plans.

Please note the exception for small employers that sponsor an HRA.

What is the reporting process?

The timing and process for meeting the ACA reporting requirements is modeled after the process for reporting employee compensation annually on Form W-2.

Forms must be provided to individuals by January 31 of the following year or by the date set by the IRS if extended
Forms must be filed with the IRS by February 28 (if paper) and March 31 (if electronic) or by the date set by the IRS if extended, accompanied by a transmittal form
Forms may be filed in paper or electronic format, but if more than 250 forms are filed with the IRS, they must be submitted electronically

In Summary

Action steps for Medical Trust Participating Groups:

Mandate	Employer Size	Action Steps
The Employer Mandate	Less than 50 full-time employees and full-time equivalent employees	No reporting requirement.
	50 or more full-time and full-time equivalent employees	File IRS Forms 1094-C and 1095-C (except for Part III). Deadline: Form 1095-C – provide a copy of 1095-C to all employees by January 31, or by the date set by the IRS if extended. File with IRS: Form 1094-C and 1095-C: Each year by February 28 if filing by paper or March 31 if filing electronically, or by the date set by the IRS if extended.
	50 or more full-time and full-time equivalent employees and sponsors an HRA	File IRS Forms 1094-C and 1095-C, including Part III to report information on HRA participants. Deadline: Form 1095-C – provide a copy of 1095-C to all employees by January 31, or by the date set by the IRS if extended. File with IRS: Form 1094-C and 1095-C: Each year by February 28 if filing by paper or March 31 if filing electronically, or by the date set by the IRS if extended.
The Individual Mandate	All	The Medical Trust or fully insured medical plan will provide the required reporting for the plans they sponsor.
	Small employers that sponsor an HRA	May be required to file separate IRS Forms 1094-B and 1095-B related to their HRA participants.

If you have any questions, please contact your Benefits Relationship Manager.

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More Information About Reporting

What is the reporting process?

In Summary