By - March 12, 2015

1095-C Forms: Questions Answered for Mastering the 1095-C Form

1095-C forms questions answered
Here are a few more questions from our webinar, “Mastering 1095-C Forms for ACA Compliance”. If you missed the webinar, you can replay it here. These questions cover measurement and stability periods, Union questions, waiting periods, and specifics on the forms.
Q: ­We have union employees. If we don’t administer benefits for them and they do not have Eligible Employee deductions, do we have to report anything for them?­

A: You do not – if the union administers benefits for their members and the employer does not take EE deductions, the union and not the employer is responsible for reporting.

Q: Is it correct that Part III on the 1095-C form is only for self insured applicable large employers? 
A: Correct – Part III of form 1095-C is only required for plan sponsors and self-insured ALE members.

Q: ­How should you count waiting periods?­

A: Waiting periods are considered limited non-assessment periods for ACA purposes, and would be coded as such in your IRS reporting.

Q: ­How would month-to-month tracking compare to other forms of tracking?

A: The examples used in this presentation were based on the look-back measurement method, but the reporting requirements would be the same for any other method of tracking.

Q: ­Would it be a good practice for the employer to have a form for any employee to sign to validate we offered coverage upon hiring, and they either declined or accepted?­

A: Since you are required to report on all offers of coverage, having validating records of such offers would be a good best practice.

Q: ­Does the 1095-C that goes to the employee have to be in this format or can it be formatted differently?­

A: An employer that is eligible for the Qualifying Offer Method Transition Relief for any employee who receives a Qualifying Offer for all 12 months of the calendar year may, in lieu of furnishing the employee a copy of Form 1095-C, furnish a statement as described in “Alternative Method of Furnishing to Employees Under the Qualifying Offer Method” section in the 1094 and 1095-C instructions. However, for an employee who enrolled in self-insured coverage, the employer must furnish the information, reporting enrollment in the coverage on Form 1095-C, Part III.

Q: ­If an employee has not completed an initial measurement period, should employers count hours monthly or weekly to determine FT/PT status?­

A: ­FT or PT status upon hire is determined by the number of hours an employee is reasonably expected to work in the position in which they’re hired.

For PT and variable-hour employees, the purpose of the initial measurement period is to track the hours worked by an employee for the purpose of determining FT/PT status by ACA definition at the end of that period, to then make a benefits-eligibility determination that is fixed during a subsequent stability period. For FT employees, the purpose of the initial measurement period is to ensure their hours worked are tracked, especially in the event of a change in status that could affect their eligibility during the initial period. This ensures that at the end of the initial period, all hours (both FT and PT) are considered in the final ACA eligibility calculations.

Q: ­When you measure employees’ time, is it best to stay consistent for each stability period? We shouldn’t do 9 months one year and then 12 months another year?­

A: ACA regulations require that your measurement and stability are setup in such a way that there are no gaps between the start and end of subsequent stability periods, that the stability periods for the initial measurement period and your standard measurement period are the same length, and that the periods you choose are consistent across all applicable employees. As long as the setup you choose meets these criteria, the details are at the employer’s discretion.

Q: ­If our stability period is July to June, and begins July 1, 2015, then what do I do about the beginning of 2015?­

A: Your liability under section 6056 as of 1/1/2015 depends on whether or not you qualify for transition relief for 2015. If you do qualify, your liability under section 6056 goes into effect at the start of your 2015-2016 plan year, regardless of how your stability period is setup. If you do not qualify, your liability is in effect as of 1/1/2015.

Q: ­Can you explain more about the 98% offer method and what that means again? ­

A: To be eligible to use the 98% Offer Method for section 6056 reporting, an employer must certify that it offered, for all months of the calendar year, affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing a Form 1095-C employee statement, and offered minimum essential coverage to those employees’ dependents. The employer is not required to identify which of the employees for whom it is filing were full-time employees, but the employer is still required to file Forms 1095-C on behalf of all of its full-time employees.­

To view the forms and instructions for filling them out follow the links below:

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