The U.S. Supreme Court’s June 25 decision once again upheld the Affordable Care Act (ACA), meaning employers subject to the act’s information reporting provision can no longer afford to put off planning in the hope that the requirements might go away.

Beginning in 2016, “large” employers defined by the act (generally employers with 50 or more full-time employees or the equivalent) must file Forms 1094 and 1095 to provide information to the IRS and plan participants about health coverage provided in the previous year (2015).

Keep in mind that, while some “midsize” employers (generally employers with 50 to 99 full-time employees or the equivalent) can qualify for an exemption from the play-or-pay provision in 2015 if they meet certain requirements, these employers still will be subject to the information reporting requirements.

Fortunately, recent IRS guidance helps clarify the reporting requirements.

If your organization is among those required to file Forms 1094 and 1095 and you need help complying with the requirements, please contact Whalen & Company.

Copyright 2015 Thomson Reuters

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