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IRS Update on ACA Draft Forms 1094-C and 1095-C and new affordability percentage

Publication Date: 8/1/2014 1:36:33 PM

According to Section 6056, larger employers must demonstrate they fulfilled employee coverage obligation per the "pay or play" rules. Forms 1095-C and form 1094-C will be used for data transmittal per IRS regulations.

HOWEVER, the IRS "2014 instructions for Forms 1094-C and 1095-C" issued on August 28, 2014 states:

"Forms 1094-C and 1095-C are not required to be filed by any employer for 2014. However, in preparation for the first required filing of these forms (that is, filing in 2016 for 2015), employers may, if they wish, voluntarily file in 2015 for 2014 in accordance with the forms and these instructions. For more information about voluntary filing for 2014, visit IRS.gov. No employer shared responsibility payments under section 4980H will apply for 2014 for any employer, regardless of whether they voluntarily file for 2014."

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IRS Bulletin:  2014-13 Information Reporting by Applicable Large Employers on Health Insurance Coverage Offered Under Employer-Sponsored Plans by clicking here

View information concerning form 1095-C by clicking here

View information concerning form 1094-C by clicking here

New guidance was issued last week from the Internal Revenue Service (IRS) regarding large employer "affordability". The previous 9.5% has been changed to 9.56% of the employee household income.