Nuts-and-Bolts: 2015 ACA Employer Reporting

Effective January 1, 2015, employers will be required to report whether they offered health insurance to their full-time employees, and, if so, which form(s) of health insurance they offered. Organizations with over 50 full-time employees will be required to submit the required data for the 2015 plan year in early 2016. Employers should start compiling the required data in January to ensure that all required data is tracked for 2015.

Those employers with more than 50 full-time employees will be required to submit their report if they have made qualifying offers to individual, full-time employees and their dependents on a per employee, per month basis. The data employers will be required to gather and submit includes:

  • Name, Address, and Social Security Number of each full-time employee including the months (if any) the employee was covered under the offered health plan
  • The number of months in which minimum essential health coverage was available and offered
  • Each full-time employee’s share of the lowest cost monthly premium for coverage (self only) for coverage by calendar month
  • The number of full-time employees employed for each month during the 2015 calendar year

Employers who participate in self-funded plans (including those organizations with fewer than 50 employees) and insurers will be required to report the overall information pertaining to the plan and the plan sponsor, in addition to data for each covered individual on the plan. Required data includes:

  • Name, Address, and Social Security Number of each covered employee
  • Months during the calendar year during which the individual was covered

The reporting entity (either the employer or the insurer) will be required to report their data by January 31, 2016, and to the IRS by March 31, 2016. Though reports will not need to be submitted until January 2016, the reporting period will begin on January 1, 2015. As of this date, employers should begin tracking the above data and must take the necessary steps now to ensure that the required data can be easily tracked prior to the first of 2015.