Many employers continue to have questions about complicated Affordable Care Act reporting requirements. Earlier this week, SourceMedia's Accounting Today hosted a Web seminar on Understanding Affordable Care Act Reporting which sought to clear some of the confusion about ACA reporting.

The event was sponsored by Greatland Corporation’s Yearli reporting platform.

Janice Krueger, subject matter expert at Greatland, spoke on ACA mandates, reporting basics, filing requirements and deadlines, and penalties.  Krueger provides guidance to the IRS, the Social Security Administration, and state agencies in the areas of form design, specification development, and filing and processing systems.

As the number of questions from the audience demonstrates, the majority of accountants are still confused by the complexity of the reporting requirements. For those who weren’t able to tune in, here are some of the more instructive questions and answers.

Question: When determining if an employer is an ALE [Applicable Large Employer] for 2015 reporting, does the employer use the employee count from 2014 or 2015?

Answer: 2014. Whether an employer is an ALE is determined each calendar year, and generally depends on the average size of an employer’s workforce during the prior year. If an employer has fewer than 50 full-time employees, including full-time equivalent employees, on average during the prior year, the employer is not an ALE for the current calendar year. Therefore, the employer is not subject to the employer shared responsibility provisions or the employer information reporting provisions for the current year.

Question: Does Form 1095-C reporting apply only to large employers that are for-profit businesses or to other large employers as well?

Answer: 1095-C reporting applies to all ALEs, including for-profit, nonprofit and government entity employers.

Question: If two or more companies have a common owner or are otherwise related, are they combined for purposes of determining whether they employ enough employees to be considered an ALE?

Answer: Yes. For example, if two companies, one with 30 full-time equivalents and the other with 40 full-time equivalents, have a common owner, the full-time equivalents are combined to determine if each separate company is an ALE. If the combined total meets the 50 full-time equivalent threshold, then each separate company is considered an ALE, even though individually the companies do not employ enough employees to meet the threshold. Each individual company would then be responsible for filing Forms 1095-C for its applicable employees along with its own authoritative Form 1094-C.

Question: If an ALE does not offer coverage to its employees, is the ALE required to file Form 1095-C?

Answer: Yes, Form 1095-C must be filed regardless of whether the ALE offers coverage or the employee enrolls in any coverage offered.

Question: If an employee waives coverage from an ALE, does the ALE need to file Form 1095-C for this employee?

Answer: Yes, Form 1095-C must be filed regardless of whether the ALE offers coverage or the employee enrolls in any coverage offered.

Question: How should information about the offer of coverage for the month in which an employee terminates employment be reported on Form 1095-C?

Answer: If an employee terminates employment on any day other than the last day of a month and the coverage or offer of coverage expires upon termination of employment, the ALE should enter code 1H on lne 14. If the coverage or offer of coverage would have continued if the employee had not terminated employment during the month, the ALE should enter code 2B on line 16 for that month.

Question: Is an ALE required to enter a code on line 16  of Form 1095-C?

Answer: No. However, an ALE can use line 16 to indicate whether the ALE qualifies for an exception to a penalty. An ALE should enter the appropriate code on line 16 if any applies. If no code is applicable for a given month, line 16 should be left blank.

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