ACA Reporting - Clarification of Key Issues for Employers

The Internal Revenue Service (IRS) has published final forms and instructions for large employers’ mandatory reporting requirements under the Affordable Care Act (ACA). The final instructions clarify various issues relating to how large employers prepare the Form 1095-C for full-time employees. Some helpful clarifications are provided, including:

  • Instructions for obtaining an automatic 30-day extension to furnish forms to the IRS;

  • Instructions for requesting an extension of time to furnish statements to employees;

  • Instructions on correcting Forms 1094-C and 1095-C;

  • Clarification that the IRS requires reporting for only one plan where employees are covered by more than one type of minimum essential coverage (such as a medical plan and an HRA);

  • Clarification that COBRA offers for terminated employees are not reported as offers of coverage under any circumstances;

  • Additional details on reporting cost of coverage for non-calendar year plans; Additional details on reporting coverage through multiemployer plans;

  • Instructions on electronic filing and how to obtain a waiver from electronic filing; and

  • Information on potential penalties and penalty relief.

Recently released IRS Notice 2015-68 also simplifies the rules for collecting Social Security

Numbers (SSNs). When an employer sponsors a self-insured plan, the employer must report the SSN for each enrolled individual (including dependents). Pending additional guidance, reporting entities will not be subject to penalties for failing to report SSNs if they request them as follows: (1) make an initial solicitation at an individual’s first enrollment or, if already enrolled on September 17, 2015, the next open enrollment season; (2) make a second solicitation within a reasonable time thereafter; and (3) make a third solicitation by December 31st of the year following the initial solicitation. In addition, plan sponsors do not have to solicit SSNs from individuals who have terminated coverage.


The IRS is encouraging employers and tax professionals to take a close look at its new webpage titled “Affordable Care Act Information Center for Applicable Large Employers (ALEs).” The webpage can be used to determine ALE status and as a means to finding additional resources on these complicated rules. According to the webpage, two provisions of ACA that apply only to ALEs are now in effect—the employer shared responsibility provision, and the employer information reporting provision for offers of minimum essential coverage. Self-insured ALEs, i.e., employers who sponsor self-insured group health plans, have additional provider information reporting requirements.


Employers are advised to consult with their tax, HRIS/payroll, and legal advisors for assistance with specific issues/complexities regarding form preparation, appropriate eligibility and hours tracking rules, and the actual implementation of the data gathering, tracking, and reporting rules. Should you have questions about this or any aspect of federal health insurance reform, contact your Conner Strong & Buckelew account representative toll free at 1-877-861-3220. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.

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