ACA Reporting Update: Some Relief And Process Streamlining For Employers

Applicable large employers ("ALEs") are subject to reporting requirements under the Affordable Care Act (the "ACA"). To comply with the reporting requirements, an ALE must file a Form 1095-C with the IRS reporting certain information about the ALE's offer of coverage to each full-time employee, identifying the employee, spouse, and dependents who are covered under the employer's self-insured group health plan, and provide a copy of the Form 1095-C to each full-time employee.

The reporting requirements provide information to the IRS that it uses to determine whether the ALE has complied with the offer of coverage rules under Section 4980H of the Internal Revenue Code of 1986, as amended (the "Code"). If an ALE fails to offer affordable, minimum-value coverage to at least 95% of its full-time employees, it can be subject to a penalty under Code Section 4980H(a). If the ALE fails to offer affordable coverage to one or more full-time employees, the ALE can be subject to