ACA Employer Reporting Requirements | Upcoming Due Dates

Despite marketplace uncertainty surrounding potential “repeal and replace” details, the 2016 Affordable Care Act (ACA) employer reporting requirements remain effective with approaching due dates.

Applicable Large Employers (ALEs) are required to report whether Minimum Value, affordable coverage was offered to any full-time employees (full-time for at least one month during the year).  Full-time equivalent employees must be included when determining if an employer is subject to the coverage penalty and reporting requirements of the ACA.

ALEs must provide Form 1095-C to employees if employing 50 or more full-time employees (including full-time equivalent employees) in the previous calendar year. The penalty for non-compliance is $260 PER-FORM.

As a reminder, on November 18, 2016, the IRS issued a 30-day extension for employers to supply employees with Forms 1095-C (1095-B, as applicable).  The date is extended from January 31, 2017, to March 2, 2017. Importantly, the date to provide the IRS with the same information was NOT extended; and remains due as of March 31, 2017.

Click HERE for an Oswald executive summary addressing changes to the 2016 reporting requirements.

Click HERE for Oswald’s step-by-step guide to the ACA employer reporting requirements.

Oswald will continue to provide proactive and concise information in implementing the strategic, financial and administrative challenges of the ACA, as well as for any replacement legislation, as clarifying regulations and modifications are issued.


Oswald Companies | Health Care Reform Implementation Review
Andrea Esselstein, J.D. | aesselstein@oswaldcompanies.com; 216.658.5012
Danielle Jarvis | djarvis@oswaldcompanies.com; 216.649.7384
Luke Clark | lclark@oswaldcompanies.com; 216.367.8758

Disclaimer: Materials are solely for informational purposes as an educational resource. Please contact counsel to obtain advice with respect to any specific issue.