Kelli Smith Selerix Systems Manager, ACA Services

ACA Dashboard User Guide designed to assist employers navigate the review and approval of the Final ACA Summary Reports. 

Instructions for 2019 Forms 1094/5-C; 2019 Form 1094-C​; 2019 Form 1095-C

The IRS has announced a welcome extension of the 2020 due date for certain entities to provide 2019 health coverage information Forms 1095-B or 1095-C to employees and individuals. Limited penalty relief is also extended to the 2019 Forms. Visit this IRS webpage for information on the health coverage forms requirement.

Due Date Extended to Issue Forms to Employees/Individuals
Insurers, self-insuring employers, other coverage providers, and applicable large employers (ALEs) now have until March 2, 2020, to provide Forms 1095-B or 1095-C to employees and individuals. The IRS has announced that further extensions beyond this new due date will not be available and the IRS will not be formally responding to extensions that have already been requested by reporting entities. The extension for filing Forms 1095-B or 1095-C to individuals is automatic. Employers and providers don’t have to request it. The IRS will not grant an additional 30-day extension beyond this deadline.

Due Date NOT Extended for Forms to IRS
The due dates for filing Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS are not extended. Therefore, employers filing by paper must submit their Forms to the IRS by February 28, 2020. Those filing electronically have until March 31, 2020. As a reminder, employers and coverage providers who are filing more than 250 of these reporting forms are required to file electronically.

Special Note on State Employer Reporting Requirements
Note that insurers and employers in certain states (e.g., Massachusetts, New Jersey and Washington, D.C.) that have enacted individual mandates are required to file the 2019 Forms 1094-B, 1095-B, 1094-C or 1095-C with the state and furnish the Forms to state residents.  More Information on state-level individual mandates available.     

Good Faith Penalty Relief
Finally, the announcement extends the program for the IRS granting good faith relief for certain errors. Employers and coverage providers who work in good faith to complete the returns or statements will not be assessed penalties due to missing or inaccurate information. This relief applies only to missing and inaccurate information required on the Forms and does not provide relief in the case of reporting entities that do not make a good-faith effort to comply with the regulations or that fail to file an information return or furnish a statement by the due dates.

We will continue to monitor developments under the Affordable Care Act and provide details on new and revised employer obligations as they take shape over time.  

States Give New Life to the Individual Mandate and Usher in Extra Reporting Requirements

As more states pass their own individual mandate, many now have their own version of employer reporting requirement.  Does your Company have to Comply with an ACA State Individual Mandate?

Although the ACA individual mandate is gone at the federal level; many states have begun to implement their own ACA state individual mandates, which require residents to purchase and maintain qualifying health coverage or face a state tax penalty.  We anticipate that more states will follow suit in pursuing ACA state individual mandates. So, employers should anticipate some reporting changes at the state level. Now is the time to determine if you have employees who reside in a state with an ACA individual mandate.

As a disclaimer, we (Selerix) are not consultants or legal counsel and can't dictate employers' decisions..  We can only offer our understanding of the expectation related to the state-level requirements outlined by individuals states.  That said, we always advise employers to seek guidance from their advisor and/or legal counsel.  
 

Which states are affected by the ACA state individual mandate?
To date, six states have passed individual mandates of which three are effective for the 2019 reporting year, the District of Columbia, Massachusetts and New Jersey.       

• California – Effective January 1, 2020
• District of Columbia
• Massachusetts
• New Jersey
• Rhode Island – Effective January 1, 2020
• Vermont – Effective in 2020

Below is what we know so far and will continue to provide updates as more information is released.

California Individual Mandate
Important dates:
Employers are required to file annually by March 30. For the 2020 tax year, the due date is currently March 30, 2021

Employer obligations:
In-state and out-of-state employers who employ California residents are obligated to provide the same data outlined in Section 6055 of the Affordable Care Act. This section specifically covers the enrolled coverage of employees while Section 6056 covers the offer of coverage to employees. Final details are not available; however, they have indicated fully insured employers will rely on their insurer to provide data to the State and self-insured employers will be required to submit their own data to the State.

Process for filing:
No details are available at this time

District of Columbia Individual Mandate
Important dates:
Employers are required to report annually, within 30 days after the IRS tax deadline. For the 2019 tax year, the due date is extended to June 30, 2020.

Employer obligations:
In-state and out-of-state employers who withhold and pay payroll tax to D.C. or who employ D.C. residents, even if the employer does not withhold D.C. payroll taxes.  ALE's sending 1095-C forms to employees and filing 1095-C and 1094-C forms with the IRS, are required to file forms with the state.  Employers who only have fully insured coverage cannot rely on the insurer to provide 1095-B forms alone, they will still need to submit 1095-C and 1094-C forms to D.C.

Process for filing:
D.C. will leverage their mytax.dc.gov portal using the Office of Tax and Revenue’s proscribed file format and has indicated this would be the same information provided to the IRS, for employers who employ non-D.C. residents, they must only include requested information in the file.

Massachusetts Individual Mandate
Important dates:
Employers are required to report annually. The reporting period is from Nov 1 to Nov 30*
(*For the 2019 tax year, the deadline is January 31, 2020)

Employer obligations:
The reporting requirement for employers with employees who reside in the state of Massachusetts relates to Form MA 1099-HC.  Most insurance companies issue the forms on the employers’ behalf and send the state a reporting listing all the Form MA 1099-HC they issued.

The Health Insurance Responsibility Disclosure (HIRD) form, is a state reporting requirement for Massachusetts Employers which collects employer-level information about their employer-sponsored insurance (ESI) offerings.  The HIRD reporting is administered by MassHealth and the Massachusetts Department of Revenue (DOR) through the MassTaxConnect web portal.

Process for filing:
Most insurance companies issue the forms on the employers’ behalf and send to the state however if the insurance company doesn’t file Form MA 1099-HC on their behalf, employers are required to upload the XML files through MassTaxConnect.   

New Jersey Individual Mandate
Important Dates:
For the 2019 tax year, the filing due date is March 31, 2020.

Employer Obligations:
In-state and out-of-state employers who employ New Jersey residents, even if the employer does not withhold New Jersey payroll taxes.
ALE's sending 1095-C forms to employees and filing 1095-C and 1094-C forms with the IRS are required to file forms with the state.  Employers who only have fully insured coverage cannot rely on the insurer to provide 1095-B forms alone, they will still need to submit 1095-C and 1094-C forms to the state of New Jersey.

Process for filing:
New Jersey will leverage the same secure transport system that is used by employers or their vendor to submit W-2 forms. New Jersey requests the same XML file format used for submitting to the IRS. However, for employers who employ non-New Jersey residents, they must edit the file in order to remove those records.

Rhode Island Individual Mandate
Important dates: 
No due dates have been set yet, but it’s anticipated employers reporting to begin in 2021 for the 2020 tax year.

Employer obligations:
No guidance has been released around employer reporting obligations.

Process for filing:
No details are available at this time.

Vermont Individual Mandate 
Important dates:
No due dates have been set yet, but it’s anticipated employers reporting to begin in 2021 for the 2020 tax year.

Employer obligations:
No guidance has been released around employer reporting obligations.

Process for filing:
No details are available at this time.

Other states that are actively considering and/or pursuing a statewide individual mandate:

• Connecticut
• Hawaii
• Maryland
• Minnesota
• Washington

Selerix will continue to monitor developments and keep employers informed as more ACA updates become available.

Thank you,

Selerix ACA Support

 

At Selerix, we support a proactive vs a reactive approach to ACA Management which has resulted in the distribution of the ACA Summary report(s) to employers on a quarterly basis.  
 

The goal of distributing the ACA Summary report(s) during the calendar year is:

• Allows employers to review the data contained within the report specifically focusing on the data found under Line 14, Line 15 and Line 16 which represent the Part II of the 1095-C Form provided to employees.
• Allows employers to have more control over their data by reviewing the information on a more frequent basis.
• Allows employers to capture any errors and/or make any employee record updates/changes earlier in the calendar year vs at year-end.

Timely review & feedback of the quarterly ACA Summary report(s) now is vital to ensure any code anomalies or errors you identify can be solved.  To aid in the process, the attached FAQs on the Form 1095-C Reporting Codes is available to assist you in the review of the data contained within the report.  To date, the IRS has not released any extensions to the form or filing process or provided a “good-faith efforts” standard.  Therefore, timeliness and accuracy are essential when completing the forms and filings to avoid potential penalties.  Don’t Wait! Take this opportunity to review the ACA Summary and provide feedback as soon as possible.

Service Partners_Guide to the ACA Workflow

Processing Guide - ACA Summary Report 2019

Guide to Understanding the 1094-C Form

Measurement Methods & Lookback Report Guide_101: Useful guide on the IRS approved Measurement Methods and the Selerix ACA Lookback Report. 

As your partner in the ACA process, we are committed to assisting in understanding the complexities of ACA compliance.   

As part of that commitment, our ACA Newsletter offers The Latest ACA News to help provide additional resources and valuable information.