If 50 or more full-time or full-time-equivalent (FTE) employees worked for your organization in the 2022 calendar year, you are still considered an Applicable Large Employer (ALE) and must provide ACA-compliant health care and report affordability and coverage to the IRS. The reporting requirements for 2022 still require employers to provide 1095-C forms to all full-time or full-time-equivalent employees, even though employees no longer need to use the forms to prove health insurance coverage when they file their personal income tax returns. Insurance carriers for fully insured plans will send 1095-B forms to employees. Employers must still file the 1094-C and 1095-C forms electronically with the IRS by March 31, 2023, or pay costly penalties.
Sponsors of self-insured group health plans have additional reporting requirements under the Affordable Care Act (ACA), even if they are not large enough to qualify as an ALE. If your medical plan is fully or partially self-funded and you are too small to qualify as an ALE, you must still provide 1095-B reporting since you are the plan sponsor. If you are an ALE with a self-funded medical plan, you must include the name, birthdate and SSN for all covered employees and dependents on Forms 1095-C, in addition to the standard ACA coverage and affordability information normally provided on those forms.
For the 2022 ACA reporting year, the federal deadline for providing 1095-B or 1095-C forms to your employees is Jan. 31, 2023. The deadline for filing your Form 1094-B or 1094-C with the IRS (along with copies of the Forms 1095-B and 1095-C distributed to employees) is March 31, 2023, (if filing electronically) or Feb. 28, 2023 (if filing via paper).
To meet ACA reporting requirements, you should compile and analyze data now to verify coverage and affordability. If you purchased Workforce Acceleration or Benefits Administration with ACA compliance, the tools you need are included in isolved HCM. Insperity’s ACA solutions also include ACA printing and IRS filing services.
For clients using isolved for ACA compliance, here are a few important deadlines:
- All ACA configuration, including history from prior years, must be completed in isolved no later thanNov. 15, 2022. If you have not yet done so, please return your completed ACA configuration template or schedule a call to discuss your configuration with the ACA team at WA_ACATeam@insperity.com.
- Once configuration is complete, you must preview, verify and approve your 1094 and 1095 forms by Jan. 21, 2023.
- 1095 forms, if approved, will be available to employees who have opted to receive electronic year-end forms in isolved HCM no later than Jan. 31, 2023, For employees who did not provide consent for electronic year-end forms, you must still send them a paper form. For those employees, Insperity will print and send their 1095-B or 1095-C forms to you in sufficient time to mail them by the IRS deadline.
- Insperity will begin submitting 1094 and 1095 electronic files to the IRS in mid-February. During the submission process, you may be asked to verify employee names and SSNs if they do not match the IRS or SSA records. You must respond in a timely manner to these requests so our ACA filing team can submit corrected information by the IRS filing deadline. To prevent filing errors, it is a good idea to ask employees now to verify that their SSN and name in isolved HCM exactly match the legal name on their Social Security card.
Note: If Insperity filed your 2021 ACA information, you will need to contact your benefits operations specialist no later than Friday, Dec. 9, 2022, to verify reporting details that may have changed since last year.