via Lockton Benefit Group

With early 2016 filing deadlines looming, the IRS recently issued draft instructions for the filing of four key reporting forms related to the Affordable Care Act’s (ACA’s) individual and employer mandates. The draft instructions serve as a reminder, for those who have begun preparing for ACA reporting, that the deadline is drawing slowly but inexorably nearer. The draft instructions are a call to action for employers who have not yet begun to prepare.

Background The ACA requires all but the smallest employers to provide a new tax form, Form 1095-C, to each of their employees who were full-time for at least one month in 2015. The form shows the extent to which the employer met the ACA’s employer mandate in 2015 with respect to that particular employee.

Lockton comment: Employers that dodged the employer mandate’s health insurance coverage obligation in 2015 because they had between 50-99 full-time and full-time equivalent employees during the relevant lookback period in 2014 are nevertheless required to comply with the employer mandate reporting obligation for 2015.

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