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.

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.

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.

  • Forms must be provided to individuals by January 31 of the following year.
  • 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.

In Summary

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)

Deadline: Form 1095-C – provide a copy of 1095-C to all employees by March 2, 2020 (extended from January 31, 2020)

File with IRS: Form 1094-C and 1095-C: February 28, 2020 if filing by paper or March 31, 2020 if filing electronically

 

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 March 2, 2020 (extended from January 31, 2020)

File with IRS: Form 1094-C and 1095-C: February 28, 2020 if filing by paper or March 31, 2020 if filing electronically

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.

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