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Approaching Deadlines

Deadlines for required reporting under the Affordable Care Act (ACA)

For Applicable Large Employers (ALE), there are specific deadlines for both furnishing information to individuals, as well as reporting to the Internal Revenue Service (IRS):

ACA Reporting Deadlines in 2018
ACA Requirement Deadline
1095-C forms delivered to employees Jan. 31, 2018
Paper filing with IRS Feb. 28, 2018
eFiling with IRS March 31, 2018

Employers that file 250 or more information returns with the IRS must file the returns electronically. Source: IRS.

Reporting Requirements

Applicable large employers (ALEs) are employers that had 50 or more full-time equivalent employees on average during the preceding calendar year. ALEs are subject to the ACA’s annual information reporting requirements, regardless of whether they sponsor a fully insured health plan or a self-funded plan. ALEs should, by the above deadlines:

  • Distribute Form 1095-C to each full-time employee (similar to Form W-2 requirements and on the same distribution schedule).
  • File Forms 1095-C with the IRS for each full-time employee, along with Form 1094-C (the transmittal form).

An IRS Q&A provides more information on 1095 filing requirements.

Small employers with fewer than 50 full-time employees are exempt from some but not all of the ACA’s reporting requirements. For example, self-insured small employers must complete and file Forms 1095-B and 1094-B (the transmittal form) with the IRS, as well as provide full-time employees with a copy of Form 1095-B.

Small employers also are required to file Forms 1095-C and 1094-C if they are members of a controlled or affiliated service group that collectively has at least 50 full-time employees.

Reporting and payment of PCORI fee

The fee is due by July 31 of the year following the calendar year in which the plan/policy year ends.

These guidelines are provided for informational purposes only, and should not be construed as legal advice or statute. Please consult with professional tax resources or legal counsel to ensure your business is in compliance with all applicable state and federal regulations.





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