MBA VEBA
Health Plan ACA Compliance Reporting for Applicable Large Employers By Joyce Kennedy, Manager of Insurance Services
an employer with 50 or more full-time or equivalent employees. Te ALE must follow ACA annual reporting rules to remain compliant for group health plan offerings.
Form 1094-C/1095-C Deadlines Annually, ALEs must provide individual statements to employees and file Forms 1094-C and 1095-C with the IRS (disclosure of certain information about the group health coverage they offer their full-time employees).
• ALEs must furnish individual statements to full-time employees for 2022 reporting no later than March 2, 2023.
• ALEs must file applicable reports with the IRS no later than Feb. 28, 2023, (paper filing) or no later than March 31, 2023 (electronic filing — mandatory for ALEs filing more than 250 forms).
2023 ACA Compliance Change — Lower Affordability Threshold Beginning Jan. 1, 2023, the lowest cost health plan offered by employers must cost no more than 9.12% of an employee’s household income for employer-sponsored self-only coverage (the threshold for 2022 was 9.61%).
Affordability Safe Harbors Tere are three safe harbors that may be used to determine whether an offer of coverage is affordable (employee household income must be considered but is typically not known).
• W-2 Safe Harbor is based on wages that an employer reports in Box 1 of IRS Form W-2.
• Rate of Pay Safe Harbor is based on an employee’s rate of income at the beginning of the coverage period, with adjustments for an hourly employee if rate of pay is decreased during the period.
• For the Federal Poverty Line Safe Harbor, coverage is considered affordable if required monthly contribution does not exceed 9.5% (adjusted annually) of the federal poverty line for a single individual for the applicable calendar year, divided by 12.
Rising Employer Shared Responsibility Penalties Penalties for failing to provide the required coverage or coverage that does not meet the required affordability/ minimum value are adjusted annually for inflation. Questions and answers regarding ESRP (note Q&A #55) can be found at
irs.gov/affordable-care-act/employers/questions-and-answers-on- employer-shared-responsibility-provisions-under-the-affordable- care-act.
If you are an ALE, please consult your payroll vendor or tax advisor for guidance on your 1094/1095 reporting.
THE MISSOURI BANKER 13
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32
