2016 ACA Changes: Prepare for Earlier Deadlines
In a recent SHRM article interview, Tango CEO, Todd Praisner addressed some of the key ACA compliance expectations employers can anticipate for their 2016 ACA filing. While the IRS eventually offered extensions for the 2015 filings, don’t bet on those same extensions for 2016 reporting requirements.
“This year employers had an extra two months to distribute forms to employees and three extra months to file with the IRS, but we haven’t seen any indication that for next year there is going to be the same kind of relief,” SHRM quoted Mr. Praisner as saying.
What does this mean for employers? The original IRS ACA reporting deadlines are in effect for 2016 filing, and employers will need to provide 1095-C forms to employees by the end of January 2017. Even though the June 30th filing is only a few months behind us, it is imperative that HR teams start preparing for the next round of compliance now. Here are the key dates:
- Forms 1095-B and 1095-C sent to employees by January 31, 2017
- Forms 1094-B, 1095-B, 1094-C and 1095-C due to IRS if filing on paper by February 28, 2017
- Forms 1094-B, 1095-B, 1094-C and 1095-C due to IRS if filing electronically* by March 31, 2017
*It is important to note that any employer with more than 250 information returns must file electronically. Employers need to be prepared to transmit and understand the process involved.
Unfortunately, the elimination of the extension relief for employers is not the only change for the 2016 filing year. In 2015, employers only needed to offer coverage 70 percent of their full-time workforce, but this year employers will be responsible for demonstrating they have offered 95 percent of their employees health benefits coverage that meets the minimum standards.
“Some employers may not understand that it’s not 95 percent [averaged out] for the year, it’s 95 percent for each one of the months,” Praisner warned. “If you had a month where you’re below 95 percent, you’re exposed,” he added. “Employers who started 2016 below the 95 percent coverage threshold, expecting to ramp up, may be in for a surprise this year if they’re not paying attention to that.”
To ensure that your organization is meeting all of the appropriate ACA deadlines, it’s important to start reviewing compliance policies now. To get a handle on 2016 here are a few key questions to ask yourself and your HR team:
- How disruptive was the ACA filing process to the organization?
- How was the ACA reporting documentation gathered? Did that work well or could it use improvement?
- Is your team equipped to manage data gathering for the 95% coverage mandate?
- Should you consider using an ACA compliance expert to help avoid penalties and better manage compliance reporting?
Categorized in: ACA