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

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.