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When do the ACA reporting requirements go into effect?

Form 1095-C, a statement of health coverage benefits, must be provided no later than March 31, 2016 to every employee who was full-time one month or more in 2015.

Applicable Large Employers (ALEs) must file Forms 1094-C and 1095-C with the IRS no later than May 31, 2016 (or June 30, 2016 if filed electronically).

Who needs to file?

For calendar year 2015, employers with 50 or more full-time employees (including full-time equivalent employees) must report healthcare coverage to employees and the IRS.

What is an ALE?

An Applicable Large Employer (ALE) is one who employs 50 or more full-time employees and full-time equivalents.

What is the definition of a full-time employee?

Full-time employees are those who average at least 30 service hours per week or 130 service hours per month. Service hours include any time, worked or not, for which the employee is paid.

What are service hours?

Service hours consist of paid time—worked time and paid non-worked time such as vacation, sick time, and holiday pay.

How are seasonal employees counted?

A business is not subject to ACA obligations if its count of full-time and full-time equivalent employees meets or exceeds 50 for 120 days or less during the calendar year. Seasonal employees are generally defined as employees performing work that is seasonal in nature for a season that typically lasts 6 months or less and occurs at the same time of year each year.

When is the right time to get started to prepare the filing documents?

The ACA information covers the calendar year 2015. In many cases, employee status in 2015 is based on service hours in in 2014 (or even late 2013). Employers should review the filing documents and ensure that they know employee full- and part-time status according to ACA rules as soon as possible. In early 2016, they will begin preparing the 1095-C forms for distribution to employees, due March 31. Submission to the IRS is due by the end of May (for paper filing) or June (for electronic filing).

What is a variable-hour employee?

Variable-hour employees are employees who work irregular or varying schedules. Employers can’t reasonably determine ahead of time whether variable hour employees will average 30 service hours per week or more. Employers use a measurement period to record and average service hours for determining ACA full-time or part-time status, which is applied during a stability period.