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Health care reform FAQ: What reporting is required by employers?

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Q: What reporting is required by employers, other than the W-2 requirements?

A: Beginning in 2014, large employers with fifty or more full-time-equivalent employees and “offering employers”[1] will have certain reporting requirements with respect to their full-time employees.[2]

Employers will have to file a return including:

  • The employer’s name, address and employer identification number;
  • A certification as to whether the employer offers its full-time employees (and dependents) the opportunity to enroll in minimum essential overage under an eligible employer-sponsored plan;
  • The length of any waiting period;
  • The months that coverage was available;
  • Monthly premiums for the lowest-cost option;
  • The employer plan’s share of covered health care expenses;
  • The number of full-time employees; and
  • The name, address, and tax identification number of each full-time employee.

Additionally, an offering employer will have to provide information about the plan for which the employer pays the largest portion of the costs (and the amount for each enrollment category).

Insurers must also report certain information to the IRS[3] as discussed in full in Healthcare Reform Facts.

Additionally, the employer must also provide each full-time employee with a written statement showing contact information for the person preparing the required return, and the specific information included in the return, for that individual employee. An employer may enter into an agreement with a health insurance issuer to provide necessary returns and statements.

For more health care reform Q&As, see:

Health care reform FAQ: How are full-time employees calculated?

Health care reform FAQ: Which benefits are not governed by PPACA?

Health care reform FAQ: How does the employer mandate tax penalty work?

[1].         An offering employer is one that offers minimum essential coverage through an employer plan and pays for some of the costs. Reporting requirements apply to these employers, regardless of size, only if the required contribution for self-only coverage by any employee exceeds 8 percent of wages. This is required because individuals whose household income exceeds 8 percent of wages are exempt from the individual mandate and may be eligible for free-choice vouchers. However, an employer would only have knowledge of the individual’s wages, not his or her household income. Because this reporting requirement is linked to wages (and not household income), it is a first step in determining whether an individual is exempt from the individual mandate.

[2].         PPACA §1502.

[3].         PPACA §1501, 1502, and 10106 adding IRC Secs. 5000A and 6055.


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