The Affordable Care Act Form 1095-C Reporting and Disclosure Requirements for Applicable Large Employers
The Patient Protection and Affordable Care Act ("ACA"), like a LEGO® structure, is made up of many interlocking pieces. Consequently, the United States Supreme Court's recent decision in King v. Burwell, regarding individual tax credit/premium subsidies for coverage under a qualified health plan, had ramifications for employers as well as individuals. The Court's decision regarding the extent of the availability of the premium subsidy also decided the extent of the requirement for individuals to maintain minimum essential coverage (sometimes called the "individual mandate") and the employer "shared responsibility" rules (sometimes called the "pay or play" rules). The decision in King also confirmed the reach of the reporting requirements that will provide the foundation for the Internal Revenue Service's administration of the premium subsidy, the "individual mandate" and the employer shared responsibility rules.
This Update focuses on the reporting and disclosing obligations of applicable large employers ("ALEs") that are subject to the employer shared responsibility rules. Generally, an ALE is an employer with at least 50 full-time or full-time equivalent employees. The reporting and disclosure requirements, along with the reporting obligations of insurers and employer sponsors of self-funded health plans, are at the heart of the IRS's administration of the interlocking pieces of the ACA.Read More