Employer
Reporting
Requirements
Starting in 2016, What You
Need to Report to the IRS for
ACA Compliance
Two Kinds of Reporting
The Affordable Care Act (ACA) requires two kinds of reporting under the
tax code:

Section 6055 Reporting – MEC Report
Used by the IRS to enforce the “individual mandate” provision of the
ACA.

Used by individuals when they file their taxes to show months during
which they were covered



Section 6056 Reporting – Shared Responsibility Report

Used by the IRS to enforce the “employer shared responsibility”
portion of the ACA

Used by individuals to prove eligibility for premium subsidy
Final regulations combined the reports into a single report
Section 6055
(MEC) Reporting
For insurers (and employers with
self-funded plans) to report who has
minimum essential coverage (MEC)
Section 6055 (MEC) Reporting

Who Needs to File?

Employers with self-funded medical plans

Carrier will file for all insured medical plans
Section 6055 (MEC) Reporting

What Gets Reported?

The IRS wants to know who was enrolled in minimum
essential coverage (MEC) to verify individual taxes for
not having coverage

A penalty will apply to anyone who doesn’t have
coverage (no more than a 3-month break is allowed),
unless they qualify for an exemption.
Section 6055 (MEC) Reporting

What Gets Reported?

Name, address, and EIN of insurer (or employer offering selffunded coverage)

Name, address, and Social Security number of each employee
who is enrolled at any time during the calendar year

Name, address, and Social Security number if available of each
covered spouse and child

Each month for which the individual was enrolled in MEC or
entitled to receive benefits for at least one day of the month.
Section 6056
(ALE) Reporting
For applicable large employers
(ALEs) to report which employees
were offered affordable, minimumvalue coverage
Section 6056 (ALE) Reporting

Who Needs to File?

Applicable Large Employers (ALEs)

Employers with 50 or more full-time or full-time
equivalent employees.
Note that ALEs with between 50 and 99 employees
are not exempt from this requirement.

All ALEs must file whether they offer fully insured
coverage, self-funded coverage, or no coverage.

Also includes aggregated groups (such as controlled
groups) but each employer member of the group
must file separately.
Section 6056 (ALE) Reporting

What Gets Reported?

EMPLOYER INFO

The name, address, and employer identification number (EIN) of
the employer

A contact person for the employer (name and telephone
number)

The calendar year for which the information is filed
Section 6056 (ALE) Reporting

What Gets Reported?

EMPLOYEE INFO:

Name, address, and Social Security number of each employee who was
offered coverage

All the calendar months during which the employee was offered group
health coverage (and, if not, a code explaining the reason) - Codes may
be used for :


“not employed”

“waiting period”

“part-time”

“not eligible”
The number of full-time employees in each month
Section 6056 (ALE) Reporting

What Gets Reported?

OTHER INFO

Certification as to whether the employer offered minimum essential
coverage to full-time employees

Whether coverage provides the required minimum actuarial value
(60%)

Whether coverage was offered to the employee, the employee’s
spouse, and/or the employee’s dependents

The employee’s monthly share for self-only coverage in the least
expensive plan offering a minimum actuarial value of 60%
Section 6056 (ALE) Reporting

What Gets Reported?

The employer will also be required to report the name,
address, and EIN of a third party filing on its behalf.

If the employer is a member of an aggregated group, it
will need to report the names and EINs of any other
aggregated group members.

The employer must also report if it is a contributing
member to a multiemployer plan.
Section 6056 (ALE) Reporting

Alternative Reporting Methods

There are two simplified reporting methods that can be
used under certain circumstances:

Certification of Qualifying Offers

Report not Identifying Full-Time Employees
Section 6056 (ALE) Reporting

Alternative Reporting:
Certification of Qualifying Offers

Employer must certify that for all months in the calendar year that the
employee was full-time the following was true:

The employer offered the employee minimum essential coverage that
provided coverage with a minimum actuarial value of 60%;

The annual cost to the employee for employee-only coverage did not
exceed 9.5% of the federal poverty level for a single individual (in 2014,
the cost could not be more than $1108.65 ($92.38 per month)); and

Employer offered minimum essential coverage to the employee’s
spouse and children , if any.

For 2015, if employer made a qualifying offer to 95% of full-time
employees , spouses and children

Report for employees receiving a qualifying offer for all 12 months will
include Employee Name, SSN and Address along with code that qualifying
offer was made
Section 6056 (ALE) Reporting

Alternative Reporting:
No Individualized Reporting with 98% Coverage

Employer offers coverage that is

minimum essential coverage

affordable (using any of the affordability safe harbor methods) and

has a minimum actuarial value of 60%
to “substantially all” (at least 98%) of its full-time employees, then the
employer is not required to include the names of full-time employees or
the exact number of full-time employees.

Form is expected to be released by the IRS soon.
Reporting
Mechanics
What you need to do
Section 6055 and 6056 Reporting

What to File


Send the following to the IRS:

One single transmittal form (1094-C) to the IRS

A separate return (1095-C) for each covered and fulltime or enrolled employee

6055 Section completed for enrolled employees

6056 Section completed for full-time employees
Send a copy of the 1095-C to each individual for whom
the 1095-C was sent to the IRS.
Section 6055 and 6056 Reporting

When and How to Provide to Employees

Copies to individuals due January 31st

Mailed to last known address of employee

Electronic filing permitted if:
 Employee consents
 Disclosure statement is provided with the consent request
 Inform employee that paper copy is available upon
request (and procedures for obtaining)
 Indicate how long the consent lasts
 Notice is provided if information is furnished on a website –
“IMPORTANT TAX RETURN DOCUMENT AVAILABLE”
 Statements on website until 10/15 of the year in which the
statement is first made available
Section 6055 and 6056 Reporting

When and How to File with IRS

Paper returns due to IRS by February 28th

Electronic returns due to IRS by March 31st
Electronic returns required for entities filing
more than 250 returns.

Filing extension is permitted up to 30 days, if:

Good cause

Extension is applied for from IRS
Begin to Gather Data

Employer will need to gather data in 2015 for the 2016
reporting (unless an alternative method is available).

Determine whether a controlled group exists that must
be aggregated

Determine whether benefits department or admin
software will maintain data
Questions? Comments?
Polestar Benefits, Inc.
412 Jefferson Parkway, Suite 202
Lake Oswego, OR 97035
(855) 222-3358
www.polestarbenefits.com
We are happy to help!
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