Reminder: Upcoming Reporting Deadlines
IRC Sections 6055 and 6056 Reporting
Applicable large employers (ALEs — those with 50 or more full-time employees (FTEs), including equivalents) in 2016 must comply with IRC Section 6056 reporting in early 2018 for calendar year 2017. Specifically, ALEs must complete and distribute a Form 1095-C to FTEs by March 2, 2018 (changed from Jan. 31, 2018). The form should detail whether the employee was offered minimum value, affordable coverage during 2017. The forms may be mailed, electronically delivered or delivered by hand (although proof of delivery in some manner is recommended).
If an employer sponsored a self-insured plan during 2017, it must comply with Section 6055 reporting in 2018. Self-insured employers with 50 or more FTEs must complete Section III of Form 1095-C detailing which months the employee (and any applicable spouse and dependents) had coverage under the employer's plan. If the self-insured employer has fewer than 50 FTEs, it must complete and distribute a Form 1095-B with such information. Again, the forms must be delivered to employees by March 2, 2018.
Employers must also file the forms with the IRS by Feb. 28, 2018, if filing by paper, and April 2, 2018, if filing electronically. Those that are filing 250 or more forms are required to file electronically. Lastly, the employer is required to a file the transmittal Form 1094-C (if filing Forms 1095-C) or Form 1094-B (if filing Forms 1095-B).
Medicare Part D Disclosure to CMS
As a reminder, employers that sponsor a group health plan that provides prescription drug coverage to Medicare Part D-eligible individuals must disclose to CMS on an annual basis whether the coverage qualifies as creditable or non-creditable. The disclosure is due no later than 60 days after the beginning of each plan year. Thus, for calendar year plans, the disclosure is due March 1, 2018.
When identifying full-time employees for employer mandate purposes, does an employer include employees from foreign countries?
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