IMA Compliance Alert

IRS Updates on 2018 ACA Reporting and THE 2018/2019 Paid FMLA Tax Credit

Final 2018 ACA Reporting Forms & Instructions

On Monday, October 1, 2018, the IRS published final versions of its 2018 ACA reporting forms and instructions. The good news is virtually nothing was changed, with just one minor formatting change where the participant names are to be entered (breaking it up from one name field to a set of 3 fields for first name, middle initial, and last name).

The deadlines remain unchanged:

• Provide statements to individuals by the end of January (Thursday, January 31, 2019), and
• Provide those statements with the transmittal cover sheet to the IRS by:
  • The end of February (Thursday, February 28, 2019) if submitting on paper, or
  • The end of March if filing electronically (since that’ll be a Sunday, the e-filing due date will be Monday, April 1, 2019).

Electronic filing with the IRS is required when issuing 250 or more of one type of form (for example, if issuing 250 or more forms 1095-C, you must e-file with the IRS, even if providing employees paper statements). Back in May, the IRS had proposed changing how you count your 250 threshold to include forms W-2, 1099, and others, but the instructions don’t adopt that counting change yet.

Employers with self-funded medical plans that are not applicable large employers (i.e., non-ALEs) must complete forms 1094-B and 1095-B. The only change is the breaking up of the participant name field into three fields for first/MI/last as mentioned above.

Applicable large employers (ALEs) will be relieved that the forms are only changed in Part III of the 1095-C to split the participant name field into three fields for first/MI/last. The 1095-C plan start month remains optional, and the code 2E relief for multi-employer union plans continues to be available.

Please let your IMA Benefits team know if you have any questions; we will continue to monitor regulator guidance and offer meaningful, practical, timely information.