Various Affordable Care Act (ACA) Provisions
Currently all applicable large employers must offer certain minimum levels of health insurance to their full-time employees or face penalties if at least one of their full-time employees obtains a subsidy to purchase coverage through an exchange.
For 2015, employers with 100 or more full-time employees must offer affordable minimum coverage to at least 70% of its full-time employees. To avoid penalties in 2016, large employers with over 50 full-time employees must offer certain minimum coverage to at least 95% of its employees in order to avoid the penalties.
For 2015, every business that provides minimum essential medical coverage to an individual during a calendar year must file an information return and a transmittal. Many filers will use Forms 1094-B (transmittal) and 1095-B (return). But, large employers subject to the employer shared responsibility provisions will report information on Forms 1094-C (transmittal) and 1095-C (form).
These forms must be provided to the employee by January 31, 2016 and must be filed with the IRS by February 28, 2016 if reporting on paper or by March 31, 2016 if reporting electronically (over 250 forms).
The ACA also prohibits employers from paying, directly or indirectly, an employee’s premium for individually acquired medical insurance. These arrangements are sometimes called “premium reimbursement plans” because they effectively reimburse the employee for the premium they pay for their own individual insurance coverage. These plans are NOT in compliance with ACA reforms. There was relief offered for small employers (less than 50 full-time employees) during 2015. This relief expires on June 30, 2015.
There continues to be relief for two premium reimbursement plans:
An S corporation can use a premium reimbursement plan for an over 2% shareholder-employee, but only until December 31, 2015.
Market reforms also do not apply to a group health plan that covers only one employee.
An employer without an ACA-compliant health plan is subject to an excise tax penalty of $100 per day per employee.
The above changes may affect you and your employees. Are you in compliance? Are you prepared for the upcoming year-end filing requirements? Please contact us with questions. We’re here to help.
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