The final forms and instructions that employers will use for 2016 reporting under the Affordable Care Act (ACA) have been released by the Internal Revenue Service (IRS). Employers that provided basic healthcare coverage on a self-funded basis in 2016 are required to report the names and social security numbers (SSNs) of all covered individuals. While this is the second year of reporting for most employers, many still struggle with the process of how to effectively report SSN’s for all covered individuals and their dependents.
If you are an applicable large employer (ALE) that employed 50 or more full-time or full-time equivalent employees during the current reporting year, you must report to the IRS whether or not you did or didn’t offer healthcare coverage by completing Form 1095-C and 1094-C.
The requirement to report enrollment information on each covered individual, including dependent names and SSNs, only applies to employers that self-fund a minimum essential coverage health plan (e.g., major medical, PPO, HDHP). For an ALE, the self-funded plan enrollment information is reported in Part III of Form 1095-C while a “small” (non-ALE) employer reports the information in Part IV of Form 1095-B.
You can review a copy of the IRS proposed regulation on TIN solicitation here.
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