ACA Reporting Deadline Reminders

The new year started off with quite a bang as SCOTUS made their ruling regarding the vaccine or test mandate, COVID at home test kits coverage requirements kicked in and more COVID developments dominated the headlines.

This article serves as a reminder for ACA Reporting Deadlines imposed on Applicable Large Employers (ALEs).

There are two components to ACA reporting requirements.

1. ALEs must furnish a 1095-C to full-time employees by March 2, 2022
2. ALEs must report 1094C and 1095C information to the IRS by March 31, 2022 (if mailing, the deadline is February 28, 2022)

There is also state-level reporting of such forms that were introduced via certain state individual coverage mandates:

CA, RI and MA require ALEs to furnish 1095C to its residents by January 31, 2022, which does not coincide with the federal deadline. This requirement introduced confusion in prior years which seemed to have led to some leniency from the applicable states to not impose penalties for failure to meet the deadline. In fact, as of this writing, the CA Franchise Tax Board (FTB) has posted that it will not impose penalties on employers who fail to provide the forms by the January 31, 2022 deadline.

Special note: CA, RI, MA, NJ and DC impose reporting requirements onto ALEs that employ workers in the applicable states.

CA, RI, MA, and NJ require certain group health plans to submit state-level reporting by March 31, 2022. However, CA applies an automatic extension and will not apply penalties for returns filed by May 31, 2022.

For more information regarding state level reporting for employers with CA residents, click here.

For more information regarding state level reporting for employers with RI, NJ, MA, or DC, please contact your IMA representative.

Summary:

ALEs offering medical coverage to CA, RI or MA residents should ensure 1095-C statements are provided to employees by the CA reporting deadline of January 31, 2022.

Special note: The CA Franchise Tax Board (FTB) has posted that it will not impose penalties on employers who fail to provide the forms by the January 31, 2022 deadline.

Additionally, employers that sponsor self-insured medical plans or MECs will need to comply with the applicable state reporting mandate by the state specific deadlines.

Written by: Michelle Cammayo

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.