New 2016 Healthcare Information Reporting Requirements

Background

The Patient Protection and Affordable Care Act of 2010 (the "ACA") imposes significant information reporting responsibilities on certain employers starting with the 2015 calendar year. These employers must file annual information returns with the Internal Revenue Service (the "IRS") and provide annual statements to their employees containing health plan coverage information. Failure to file the required information returns (or filing incomplete or incorrect forms) could result in reporting penalties and penalties under the ACA's shared responsibility provisions.

IRS Form 1094-C and IRS Form 1095-C

Employers that employed an average of at least 50 full-time or full-time equivalent employees during the preceding calendar year (the so-called "applicable large employers") will be required to file IRS Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and IRS Form 1095-C (Employer-Provided Health