More Information About Reporting
Following is detailed information regarding the tax forms employers need to file under the ACA, and which tax forms the Medical Trust and insurers will file.
Updates - December, 2016
Extension of IRS Reporting Deadlines
The Internal Revenue Service (IRS), recognizing that many employers and health insurance issuers and sponsors of self-funded group health plans may need additional time to prepare reports under the new ACA requirements, announced an automatic extension of ACA reporting deadlines for the 2016 forms due in 2017.
- Forms 1095-B and 1095-C do not need to be provided to individuals until March 2, 2017. The original deadline was January 31, 2017.
- Forms 1094-B /1095-B, and 1094-C / 1095-C filed in paper form are due to the IRS on February 28, 2017.
- Forms 1094-B / 1095-B, and 1094-C / 1095-C filed electronically are due to the IRS on March 31, 2017.
See IRS Notice 2016-70 for more information. See below for filing details.
Delay for Cadillac Tax
Under the ACA, health insurance issuers and sponsors of self-funded group health plans (such as the Medical Trust) will be assessed an excise tax (the Cadillac Tax) on any benefit provided to employees that exceeds a pre-determined threshold. The excise tax was originally scheduled to take effect January 1, 2018, but a law delaying the excise tax until January 1, 2020 was enacted in December 2015. The Medical Trust will communicate any impact this delay will have on the healthcare plan options for 2017 and beyond during Open Enrollment this year.
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 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 plan subscribers 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 a large employer is subject to excise taxes under the Employer Mandate and 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 as defined above, 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.
- 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.
- 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
The Medical Trust has provided a guide to the Employer Shared Responsibility Provision. It is available on cpg.org for administrators who have access to MLPS or ER.
- Sign in to your CPG account.
- You’ll find a link to the document on the Administration page after you sign in.
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.
- You and other organizations in your diocese 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 2015-68 and 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 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 IRS will use these tax forms to determine whether individuals and their dependents are subject to excise taxes under the Individual Mandate.
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.
|1095-B||March 2, 2017(extended from January 31, 2017)|
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 the the IRS.
February 28, 2017 if by paper
March 31, 2017 if electronically
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 new reporting requirements is modeled after the process for reporting employee compensation annually on Form W-2.
However, recognizing that many employers and health insurance issuers and sponsors of self-funded group health plans may need additional time to prepare reports under the new ACA requirements, the IRS announced an automatic extension of ACA reporting deadlines for the 2016 forms due in 2017.
- Forms must be provided to individuals by January 31 of the following year. This deadline was extended to March 2, 2017 for 2016 reporting.
- Forms must be filed with the IRS by February 28 (if paper) and March 31 (if electronic), accompanied by a transmittal form.
- Forms may be filed in paper or electronic format, but if more than 250 forms 1095-C are filed with the IRS, they must be submitted electronically.
We have provided a sample letter that you may send to the organizations in your group that explains some of the new tax reporting rules and may help them get started in complying with these requirements. As the information contained in the letter is technical in nature, we recommend you make no content changes and only modify it to address your related entity employer contacts and to provide your contact information.
To summarize the 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)
|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
|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 IBAMS Regional Account Specialist or Director.
Please note that this update is provided to you for informational purposes only and should not be viewed as investment, tax, legal or other advice. Please consult your own professional advisors for further guidance.
Health benefits are offered through plans maintained by Church Pension Group Services Corporation (doing business as The Episcopal Church Medical Trust), 19 East 34th Street, New York, NY 10016.