If health care reporting wasn't complicated enough, Republicans' proposed Affordable Care Act (ACA) replacement plan, known as the American Health Care Act (AHCA), muddies the waters even further.
Related: Congress is in over its head on AHCA
As your clients work to fulfill their 2016 reporting obligations by the March 31 deadline, they likely have many questions about what, how, and even if they still have to file for the 2016 ACA reporting year.
Here are five of the most common ACA questions that we answer at SyncStream Solutions.
1. Republicans recently introduced an ACA replacement plan. Do we still need to comply with the ACA?
True, the AHCA would eliminate the penalty for failing to provide minimum essential coverage to employees, effectively repealing the employer mandate. However, it's still just a proposal. The bill will likely undergo many iterations before it ever crosses President Trump's desk, and we have no way of knowing what the final plan will look like.
For now, all requirements and deadlines associated with the ACA are still in place, so employers should complete their filing and reporting as they normally would this season. Employers must provide employees with the 1095-C, file on time with the IRS, and make a good faith effort to get the information right to avoid IRS penalties.
2. What is Form 1095-C?
The 1095-C is the form that indicates whether and when an employer offered health insurance coverage to its employees at an affordable rate. It's how the IRS tracks which employers are complying with the ACA's employer mandate.
3. Which employees should receive a 1095-C?
All applicable large employers — those who maintained 50 or more full-time equivalent employees in the previous calendar year — are required by the IRS to distribute a 1095-C to all full-time employees that worked for the company at least one month during the previous year; all ACA full-time equivalent employees (those who worked on average 30 hours a week); and all part-time employees who were offered and enrolled in health care coverage, but only if the employer offered self-insured coverage.
4. What is Form 1094-C?
Form 1094-C is essentially the cover letter that is submitted to the IRS alongside an employers' 1095-Cs. It summarizes information about the employer, including how many 1095-Cs are being filed, whether minimum essential coverage was offered, and whether an applicable safe harbor was used. Any employer required to submit 1095-C forms must also file the 1094-C.