Common ACA Reporting Questions

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As deadlines for the first Affordable Care Act (ACA) information reporting get closer, many employers are asking some common questions about Forms 1095-C – do we have to report on retirees and what about employees who waive coverage?

Retired in a Previous Year:  If an employer has a self-insured plan and an individual who retired in a previous calendar year (i.e., she was not an employee in 2015) enrolled in the self-insured plan, then the employer must report on the retiree under Internal Revenue Code (IRC) section 6055.  Code 1G would be used on Line 14 of Form 1095-C for all 12 months, Lines 15 and 16 would be left blank, and Part III would be completed to indicate the months the retiree was enrolled in the plan.

Retired in 2015:  If an employer has an ACA defined full-time employee who retired in 2015, then the employer must report on the individual for all 12 months of 2015 under IRC section 6056 on Form 1095-C.  Employers with part-time employees who retired in 2015 do not need to be reported on unless they enrolled in self-insured coverage for any month in 2015 (for IRC section 6055 reporting purposes).

Employee Waives Coverage:  If an employee is an ACA defined full-time employee, then the employer must report on the employee under IRC section 6056 even if they waive coverage.  Note, there are no specific codes for Lines 14 or 16 for waiving coverage.  Instead, employers should use the codes applicable for the type of coverage offered to the employee.