Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your broker, tax advisor, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to email@example.com. The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).
Q: My organization is an ALE, and our plan year is different than the calendar year. What time period does the 1095-C report cover?
You should report for each month of 2015 the employee was with your organization on their 1095-C, regardless of which month your 2015/16 plan year begins.
For the months of 2015 prior to the start of your 2015/16 plan year, you may be eligible for transition relief from the penalties under section 4980H. To be eligible for relief, your organization must have maintained a non-calendar-year plan as of December 27, 2012, and not modified the plan after December 27, 2012 to begin at a later date.
The relief is available if 70 percent of full-time employees (under eligibility terms of the plan as in effect on Feb. 9, 2014), are eligible and offered coverage as of the first day of the 2015/16 plan year, and the coverage offered is affordable and provides minimum value. There are additional transition relief requirements for employees that were not eligible and not offered coverage in 2015 (under eligibility terms of the plan as in effect on Feb. 9, 2014) prior to the start of the 2015/16 plan year.
For more details on being eligible for the relief, and for how to report this on the 1094-C and 1095-C forms, see the IRS “2015 Instructions for Forms 1094-C and 1095-C”, beginning on page 16, here.
If the circumstances are met, the relief applies so that an employee and his or her dependents may be treated as being offered minimum essential coverage during the period prior to the start of your 2015/2016 plan year, even if the employee was not actually offered minimum essential coverage. You can then report the employee as being offered minimum essential coverage providing minimum value that is affordable for the months prior to the 2015/16 plan year start.
Be sure to complete the “Plan Start Month” field as a two-digit number (e.g., plan year beginning July 1 would be “07”) in Part I of the 1095-C form to indicate you have a non-calendar year plan.