Everyone in the benefits world knows that the Patient Protection and Affordable Care Act (PPACA) is about to create an avalanche of new employee counting, coverage tracking and reporting requirements for employers.

But analysts at ACAtrack.net, a PPACA compliance automation firm, say they think many “applicable large employers” (ALEs) are still thinking in hazy terms about PPACA reporting requirements that will clamp down at some point in time, without fully understanding that the current Internal Revenue Service schedule calls for ALEs to start keeping the Form 1095-C tracking data in 2015 and filing the actual 1095-C forms in early 2016.

“Many employers don’t understand they need to make an attempt [at compliance] starting Jan. 1,” the firm says. “The fines are substantial.”

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To learn more about the ALE PPACA reporting requirements that are about to kick in read on.

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1. The actual compliance dates are a mystery.

One obvious PPACA compliance challenge is that federal agencies seem to write PPACA compliance schedules in vanishing ink. Titanium deadlines can loom over employers’ heads for years, then suddenly move back a year.

At press time, the IRS had released only drafts of Form 1095-C — the W-2 equivalent for PPACA World — and the Form 1095-C instructions.

Compliance specialists say the best approach is to assume the Internal Revenue Service (IRS) will stick to its timeline guns this time, then breathe a sigh of relief if it provides last-minute transitional relief.

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2. Large employers (probably) have their work cut out for them in 2015.

Assuming that the new PPACA ALE tracking rules take effect on schedule, they will apply in 2015 to employers with 100 or more full-time equivalent (FTE) employees; to self-insured employers with 51 to 99 FTEs; and to insured employers with 50-99 FTEs that make big changes to coverage and fail to qualify for “transitional relief.”

Employers will use Form 1095-C — “Employer-Provided Health Insurance Offer and Coverage” — to track coverage access and employee premium share information on a monthly basis.

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3. ALEs (probably) will face more filing excitement in 2016.

An employer that has to track the Form 1095-C data in 2015 must send each primary insured a copy of that insured’s Form 1095-C by Jan. 31, 2016.

An ALE is supposed to use a 1094-C transmittal form to file all of the 1095-C forms with the IRS by Feb. 28, 2016.

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