The Patient Protection and Affordable Care Act, referred to as The Affordable Care Act (ACA), is health care reform that is extremely complex, and many of the provisions apply to nonprofit organizations. Employers, including nonprofit organizations that provide minimum essential coverage to an individual during the calendar year, are required to provide some form of reporting in early 2016 for 2015 calendar year coverage.
Health insurance issuers, self-insured employers, government agencies, and other entities that provide minimum essential coverage to an individual during 2015 must report certain information about the coverage to the IRS and to the individual covered. For employers that are fully-insured, the Form 1095-B should be issued by the insurance company to the IRS and a copy provided to the covered individual. An example of this is the employer pays premiums to an insurance carrier; the insurance carrier in turn pays the health insurance claims (Blue Cross Blue Shield for example). Your insurance carrier is required to prepare the Form 1095-B.
The reporting form requirement is different for employers with 50 or more full-time employees, including full-time equivalent employees (applicable large employers). Instead of filing Form 1095-B, applicable large employers must file Form 1095-C with the IRS and provide a copy to the covered individual. For applicable large employers that are fully insured, the insurance carrier may still prepare Form 1095-B; however, that does not dismiss the employer from needing to file Form 1095-C. If you contract an outside service provider to perform your payroll, Form 1095-C may be prepared for you, but we still recommend you contact your provider to verify.
Form 2015 calendar year coverage, Forms 1095-B and 1095-C, along with transmittal Forms 1094-B and 1094-C are due to the IRS by February 29, 2016, if filing on paper, or March 31, 2016, if filing electronically. A copy of Form 1095-B or 1095-C is due to the individuals covered by February 1, 2016.
We suggest you contact your payroll provider and insurance carrier regarding the reporting requirements under the ACA. You also may want to discuss this with your Human Resources Department regarding the process for counting full-time employees to determine if you are an applicable large employer. If you are an applicable large employer and do not offer health insurance coverage to your full-time employees, offer coverage that is deemed unaffordable, or offer coverage that did not provide minimum value, you may be subject to the employer shared responsibility payment (penalty).
I joined Hawkins Ash CPAs in August 2010, and am currently the Director of Tax. From the Firm's Medford office, I provide a variety of tax services, including trust and estate tax preparation and planning. I provide these services to small business, individual, trust, estate, and non-profit clients.
