Tuesday, November 19, 2019

Top 6 Questions Answered for Mastering the 1095-C Form Online


 

Here are a few more questions “1095-C Forms Online for ACA Compliance”. These questions cover measurement and stability periods, Union questions, waiting periods, and specifics on the forms.
Q: ­We have union employees. If we don’t administer benefits for them and they do not have Eligible Employee deductions, do we have to report anything for them?­
A: You do not – if the union administers benefits for their members and the employer does not take EE deductions, the union and not the employer is responsible for reporting.

Q: Is it correct that Part III on the 1095-C form is only for self-insured applicable large employers?
A: Correct – Part III of form 1095-C is only required for plan sponsors and self-insured ALE members.

Q: ­How would month-to-month tracking compare to other forms of tracking?
A: The examples used in this presentation were based on the look-back measurement method, but the reporting requirements would be the same for any other method of tracking.

Q: ­Would it be a good practice for the employer to have a form for any employee to sign to validate we offered coverage upon hiring, and they either declined or accepted?
A: Since you are required to report on all offers of coverage, having validating records of such offers would be a good best practice.

Q: ­How should you count waiting periods?
A: Waiting periods are considered limited non-assessment periods for ACA purposes, and would be coded as such in your IRS reporting.

Q: ­When you measure employees’ time, is it best to stay consistent for each stability period? We shouldn’t do 9 months one year and then 12 months another year?
A: ACA regulations require that your measurement and stability are setup in such a way that there are no gaps between the start and end of subsequent stability periods, that the stability periods for the initial measurement period and your standard measurement period are the same length, and that the periods you choose are consistent across all applicable employees. As long as the setup you choose meets these criteria, the details are at the employer’s discretion.

Q: ­Does the 1095-C Form Online that goes to the employee have to be in this format or can it be formatted differently? ­
A: An employer that is eligible for the Qualifying Offer Method Transition Relief for any employee who receives a Qualifying Offer for all 12 months of the calendar year may, in lieu of furnishing the employee a copy of Form 1095-C, furnish a statement as described in “Alternative Method of Furnishing to Employees Under the Qualifying Offer Method” section in the 1094 and 1095-C instructions. However, for an employee who enrolled in self-insured coverage, the employer must furnish the information, reporting enrollment in the coverage on 1095-C Form Online.

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