Lerch, Vinci & Higgins, LLP





ACA & New Employer Reporting Requirements

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December 21, 2015



The Affordable Care Act (ACA) reporting requirements will directly impact all entities that are part of State Health Benefits.  In March and November 2015, the Division of Pensions and Benefits sent letters to all entities participating in the State Health Benefits Program (SHBP) and School Employees’ Health Benefits Program (SEHBP) stating that the local employer is its own entity; having its own EIN and is considered an autonomous tax entity in the eyes of the IRS.   Consequently, each individual local employer is responsible for adhering to the ACA reporting requirements. Since the State Health Benefit program is considered a self-insured program despite the use of insurance companies to administer the benefits, the local employer is required to prepare additional ACA reporting, which is usually prepared by the insurer.
 
Form 1095’s must be prepared and distributed to all employees by 1/31/16. Employers should use Form 1095-B or Form 1095-C depending on the number of full-time equivalents. Both forms include information about each insured individual and, if applicable, their covered spouses and dependents.
 
Employers are required to prepare these forms for each full-time employee (regardless of whether they are receiving health coverage from them), each part-time employee who is receiving health coverage, all retirees that are receiving health coverage from the employer,  and all terminated employees who had COBRA continuation coverage during the current calendar year.
 
If you have any questions concerning the preparation of the ACA reporting forms or the calculation of full-time equivalents, please feel free to contact Debby Golle at our offices or via email.  Her e-mail address is dgolle@lvhcpa.com.

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