The IRS Gives Employers Some ACA Breathing Room

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On Monday, December 28, the Internal Revenue Service (IRS) gave employers an early New Year’s surprise in the form of Notice 2016-4 which extends the due dates for meeting the 2015 Affordable Care Act (ACA) reporting requirements for employers, insurers and other providers.

Here is what you need to know:

  • The new IRS deadline for providing 1095-C forms to employees changed from February 1, 2016 to March 31, 2016. As a result, if needed, the due date for employers to approve the accuracy of these forms in PlanSource from January 15, 2016 to March 15, 2016.
  • The new IRS deadline for filing 1094-C forms to the IRS changed from March 31, 2016 to June 30, 2016. As a result, if needed, employers will have until June 20, 2016 to approve the forms for transmission to the IRS. 

If your organization is using the PlanSource ACA capabilities you have two options:

  • Option 1:  If your organization is current with all of the data required to generate the 1094-C and the 1095-C, please continue with the original schedule. The forms will be ready for approval on January 15, 2016. You can continue with the original filing schedule.
  • Option 2:  For those who would like to take advantage of the additional time, all data must be loaded into PlanSource no later than February 28, 2016. This data includes:
    • Payroll to the earliest measurement date for variable hour employees and full-time employees not using weekly equivalency
    • Safe harbor indices for affordability determination

If you or your customer have not been on the PlanSource system for the entire 2015 calendar year, the following data will be required for the months the PlanSource system was not used:

    • Offers of coverage for 2015
    • Self-insured enrollees for 2015 (if applicable)

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