By Jennifer Carsen, JD, Legal Editor

Few would claim their favorite season is “tax season,” and this year large employers have yet another reason to dread it: Mandatory filing requirements dictated by the Affordable Care Act (ACA) kick in for 2015.

If you are an Applicable Large Employer (ALE), it’s important to note that you are responsible for filing Form 1094-C and Form 1095-C in early 2016—not your health insurance carrier or plan administrator.

ALEs are generally employers with 50 or more full-time employees, including full-time equivalent employees, in the previous year. Bear in mind that you are still subject to this IRS reporting requirement even if you fall into the 50- to 99-employee range that is protected from ACA penalties until 2016.

For more information on ALEs and ACA penalties, see our informative ACA infographic.

Final versions of IRS forms recently released

The IRS recently released the final versions of two key 2015 forms and the related instructions that employers and insurers will send to the IRS and individuals this winter to report health care coverage they offered or provided.

The IRS published these forms in 2014 and released draft forms and instructions for 2015 this past summer. The final forms and instructions for 2015 are largely unchanged from the previously released drafts (though you should never file draft versions of IRS forms; the IRS is not a fan of this).

Though the forms were available for voluntary use in tax year 2014, the upcoming tax season will be the first time that reporting is mandatory.

What ALEs must file

ALEs must file:

1. One or more Forms 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. In plain English, this form asks for overview information about you, the ALE offering health insurance coverage, and the number of employees who qualified for this coverage in 2015. Instructions for Form 1094-C are here. Whether you file one or multiple 1094-Cs, one of them must be designated as the “Authoritative Transmittal.”

and

2. One Form 1095-C, Employer-Provided Health Insurance Offer and Coverage Insurance, for each employee who was a full-time employee for any month of calendar year 2015. You are generally required to provide a copy of the Form 1095-C to each employee. Instructions for Form 1095-C are here. This form drills down to requesting more specific details about employees covered by your health plan, including their names, Social Security numbers, dates of birth, and covered months (if they weren’t eligible for all of 2015). You also need to provide details about the type and price of coverage, as well as info relating to the safe harbor method of counting employees, if applicable.

Deadlines Are looming

Forms 1095-C are due to each of your employees by February 1, 2016. Forms 1095-C, 1094-C, and attachments are due to the IRS by March 31, 2016 if filing electronically and by February 29, 2016 (Happy Leap Year!) if filed on paper.

If you are required to file 250 or more information returns, you must file electronically.

Tax time may still seem like a ways off, but these forms are detailed and demanding, to say the least, and—as ever—penalties for noncompliance are steep. Start getting your ducks in a row now to avoid a highly stressful early 2016!

One more thing: Two additional forms

You may also hear about Form 1094-B and Form 1095-B; these are primarily used by insurers and health coverage providers, which includes employers that sponsor self-insured plans. Instructions for these forms are here.