Benefit plan managers are coming back to some of the same old nagging problems as they set about trying to comply with Patient Protection and Affordable Care Act (PPACA) requirements.
“Applicable large employers” (ALEs) are supposed to send 1095-C forms describing their employees’ coverage to the employees, and to the Internal Revenue Service (IRS), in early 2016.
See also: Meet the 2015 PPACA tax forms
PPACA Section 4980H requires ALEs to offer full-time employees affordable coverage with a minimum value or else face the risk of having to pay penalties.
In some cases, employers can document that they offer adequate coverage by simply checking a box on the 1095-C. Federal agencies have created a safe harbor rule employers can use to decide whether they can just check the box or must provide more documentation.
The IRS and other agencies have been rushing to get the batches of interpretations that advisors need to use the Section 4980H safe harbor and other PPACA forms, procedures and interpretations out the door, but Erin Sweeney, a benefits lawyer at Miller & Chevalier, said in an interview that she is still running into areas of confusion.
One example is the long-running debate about what employers with unionized employees should do about multiemployer coverage.