ACA Reporting Changes for 2016

As we draw closer to the end of 2016, it is time for Applicable Large Employers (ALEs) to start preparing for the 6056 Reporting due in 2017.  Below is a summary of changes from 2015 to 2016 in which you should be aware.

 

 2015 Reporting

2016 Reporting

Determining ALE Reporting Status
  • Transition relief permitted use of any consecutive 6-month period in 2014.
  • Transition relief no longer applies; ALE determination based on 2015 calendar year.
Affordability Safe Harbors
  • Affordability threshold 9.56%
  • Federal poverty level $11,770
  • Affordable FPL premium $93.77
  • Affordability threshold 9.66%
  • Federal poverty level $11,880
  • Affordable FPL premium $95.63 (+2%)
Non- Compliance of the 4980(a) Penalty
  • Employers with 100 or more FTEs must offer coverage (Transition Relief for ALEs with 50-99 FTE).
  • Coverage must be offered to 70% of all full-time employees.
  • When calculating the 4980(a)ull-time employee count is reduced by 80.
  • 4980(a) annual penalty of $2,080 per full-time employee.
  • Employers with 50 or more FTE must offer coverage (Transition Relief no longer available).
  • Coverage must be offered to 95% of all full-time employees.
  • When calculating the “A” penalty, the full-time employee count is reduced by 30.
  • 4980(a) annual penalty of $2,160 per full-time employee.
IRS Reporting (1094-C/1095-C)
  • Employee statements due March 31, 2016.
  • IRS eFile due June 30, 2016.
  • Employee statements due January 31, 2017.
  • IRS eFile due March 31, 2017.

 

DISCLOSURE

The information provided herein is intended solely for the use of our clients. You may not display, reproduce, copy, modify, license, sell or disseminate in any manner any information included herein, without the express permission of the Publisher or Publishers of articles within.

The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.