Pub. 14 2015-2016 Issue 1

N E W J E R S E Y C O A L I T I O N O F A U T O M O T I V E R E T A I L E R S 33 new jersey auto retailer W W W . N J C A R . O R G 1094-C (for the IRS) and 1095‑C (for the IRS and employee): • The employer’sname, address,EIN, andcalendar year of reporting • The name and telephone number of the employer’s contact person • A certification as to whether the employer offered its full-time employees and their dependents the opportunity to enroll in minimum essential coverage, by calendar month • Themonths during the calendar year forwhichminimumessential coverage was available • The total employee count and number of full-time employees for each calendar month during the calendar year • For each full-time employee, the employee’s share of the lowest- cost monthly premium for self-only coverage by calendar month • The name, address and TIN of each full-time employee during the calendar year and the months during which the employee was covered. • The total number of Forms 1095-C filed • Whether the employer is eligible for certain transition relief (such as transition relief for mid-size employers of between 50-99 full- time employees) • Whether the employee was in an initial measurement period, per- missible waiting period, or other period during which an employer penalty may not apply • Any affordability harbor applicable to the employee for that cal- endar year Large employers that are self-funded, and thus also subject to report- ing under IRC Section 6055, should file a combined report using Form 1094-C and Form 1095-C. A designated government entity may report on behalf of a governmental unit that is part of or related to the same governmental unit as the employer. Deadlines In a process similar to distribution of FormW-2s, employers can use Form1095-B or 1095-C to provide each employee with an employee statement no later than January 31st. The statement can be provided at the same time as the FormW-2, and may be furnished electroni- cally if specific requirements are met and the recipient affirmatively consents to electronic delivery. After providing the employee statements, employersmay then report to the IRS using a single transmittal form, Form 1094-B or 1094-C, compiling the employee statements. The deadline for employer filing of the transmittal form depends on whether an employer is permitted to file on paper or must file electronically. Employers filing fewer than 250 returns may opt to file on paper no later than February 28 each year, or may choose to file electronically by March 31. Employers filing250ormore returns are required to file electronically byMarch 31 annually. In 2016, thismeans that employers can report on 2015 data by providing a copy of the Form 1095, or a substitute statement, to each employee by February 1, 2016, and may then transmit Form 1094 to the IRS by either February 29, 2016 (paper) or March 31, 2016 (electronic). NOTE: This is only a brief summary that reflects our current under- standing of select provisions of the ACA. All of the interpretations contained herein are subject to change as the appropriate agencies publish additional guidance. Kelli Personette is a Health Care Reform Consultant with American Fidelity Administrative Services, LLC, where she is responsible for helping employers with their healthcare reform requirements. She can be reached at 574.292.8928.