Quick Reference Guide: 2018 ACA Employer Reporting Requirements

The Hays Research and Compliance Team has assembled a quick reference guide for 2018 calendar year reporting. This guide is specifically relating to 2018 ACA Employer Reporting Requirements.

 


Section 6055 & 6056 Reporting

Non-ALEs sponsoring insured plans are not required to report
under either Section 6055 or Section 6056

 


Forms

Forms 1094-A & 1095-A
  • Marketplace (exchange)
Forms 1094-B & 1095-B
  • Issuers, non-ALE (less than 50 FTE) that are self-insured
Forms 1094-C and 1095-C
  • Applicable Large Employer (ALE)

 


Due Dates

Form 1095: March 4, 2019
  • Paper delivery
  • Electronic only if the individual has consented to electronic delivery of the 1095 (in writing)
Form 1094: February 28, 2019
  • April 1, 2019 if filing electronically
  • Electronic filing required for ALE with 250 or more 1095s

 Employers may file for an automatic 30 day extension via Form 8809

 


Form 1095-C Line 14 Codes

1A     Qualifying Offer: MEC/MV offered to employee, self-only coverage < than 9.56% single – 2018 federal poverty line and at least MEC offered to spouse & dependent(s)

1B     Minimum essential coverage providing minimum value offered to employee only

1C     MEC/MV offered to employee and at least MEC offered to dependent(s) (not spouse)

1D     MEC/MV offered to employee and at least MEC offered to spouse (not dependent(s))

1E     MEC/MV offered to employee and at least MEC offered to dependent(s) and spouse

1F     MEC but NOT MV offered to employee, or employee and spouse or dependent(s), or employee, spouse and dependents

1G     Offer of coverage to employee who was not full-time for any month of the calendar year and who enrolled in self-insured coverage for one or more months of the calendar year

1H     No offer of coverage (or employee offered coverage that is not MEC)

1I     Reserved

1J     MEC/MV offered to employee and at least MEC conditionally offered to spouse (but no MEC offered to dependents)

1K    MEC/MV offered to employee and at least MEC offered to dependents and at least MEC conditionally offered to spouse

 


Form 1095-C Line 16 Codes

2A     Employee not employed during the month

2B     Employee not a full-time employee

2C     Employee enrolled in coverage offered

2D     Employee in a section 4980H(b) Limited Non-Assessment Period

2E     Multiemployer interim rule relief

2F     Section 4980H affordability Form W-2 safe harbor

2G     Section 4980H affordability federal poverty line safe harbor

2H     Section 4980H affordability rate of pay safe harbor

2I     Reserved

 


COBRA

COBRA for terminated employee:
  • Coverage goes to end of the month in which employee terminates (1E, 2C)
  • Coverage does not go to the end of the month in which employee terminates (1H, 2B)
  • All months following the month in which the employee terminates (1H, 2A)
  • COBRA participants who have not been employed at any time during the calendar year (1G)
COBRA for drop in hours:
  • For a person who had family coverage and was therefore offered COBRA for self, spouse and dependents: (1E, 2C) fill in line 15
  • For a person who had self only coverage and was therefore offered COBRA for self only: (1B, 2C) fill in line 15
  • For a person who had coverage for self and a dependent and was therefore offered COBRA for self, and their dependent: (1C, 2C) fill in line 15
  • For a person who had coverage for self and their spouse and was therefore offered COBRA for self and their spouse: (1D, 2C) fill in line 15

Use 2B if COBRA is not elected

 


Self-Insured Employers

Former Employees and Other Non-Employees
  1. Retirees
  2. COBRA beneficiaries
  3. Non-employee directors
    • No requirement to certify OFFER of coverage, but still must report coverage provided
      • Self-insured sponsors may use either Forms 1094/1095-C or Forms 1094/1095-B
      • If using 1094/1095-C, use Code 1G on line 14

Code 1G goes in all the 12 months column on line 14

 


Special Rules for HRAs

Self-insured major medical plan and an HRA
  • Report only the major medical plan information
Insured major medical plan and an HRA
  • Not required to report if the individual is eligible for the HRA because the individual enrolled in the insured major medical plan
Part III
  • HRA must be reported in Part III for any individual who is not enrolled in a major medical plan of the ALE Member
  • Applicable to the employers with less than 50 FT/FTEs too

 


Resources

2018 Instructions for Forms

2018 Form 1095-C

2018 Form 1094-C

 


Disclaimer:

These quick reference materials are provided for general information purposes only and should not be considered legal or tax advice or legal or tax opinion on any specific facts or circumstances. Readers and participants are urged to consult their legal counsel and tax advisor concerning any legal or tax questions that may arise.

Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter.