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Tuesday, 05 December 2017 12:13

1095 Forms – “The Law of the Land” for Now

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Although there is much speculation about the future of The Affordable Care Act (ACA), the requirements for certain reporting is still the law of the land for now. For all large employers, and small employers that are partially self-funded, the deadline of January 31st to distribute 1095-Bs and 1095-Cs to employees is fast approaching. 

Applicable large employers with 50 or more full time equivalents are responsible for furnishing their employees with a Form 1095-C by Wednesday, January 31, 2018. Employers are still responsible for filing copies of Form 1095-C with the IRS by Wednesday, February 28, 2018 if filing by paper, or Monday, April 2, 2018, if filing electronically (same as Form 1094-C). Smaller employers who use partially self-funded plans are responsible for sending 1095-B forms, as well as copies to the IRS, by the same deadlines.
Section 6055 of the ACA requires these reports to be sent to all employees and their dependents that received medical coverage any time in 2017. These forms help the IRS determine if minimum essential coverage is being offered under the employer mandate. The forms also help enforce the individual mandate, although that was repealed effective 1/1/2019 with the Tax Cuts and Jobs Act passed this week by Congress and that the President is expected to sign.  Most organizations do not typically collect Social Security Numbers for their employees’ dependents, however, this is a necessary item in completing these forms. 
If you haven’t already collected dependent SSNs, how do you go about getting them quickly? In the age of identity theft, you may have employees that are reluctant to supply them. While there is no model language provided by the IRS to obtain them from employees, we suggest the following language:
“___Group Name___ is required by the IRS to provide important tax forms to employees and their dependents each year. To complete our obligation, we request that you provide the SSNs for your dependents ASAP to Human Resources.”

Here are some tips for obtaining the information you need moving forward:

  • Request the SSNs of all dependents at the time of hire of an employee as part of their required paperwork. (There are other reasons you may need a dependent’s SSN, such as the Medicare Data Match program). 
  • Schedule a year-end clean-up project to collect any missing SSNs. Think about any marriages or births during the past year, or other instances where you may not have new dependent SSNs.
  • You don’t need to request an SSN from a terminated EE for the purposes of ACA reporting.
  • If you cannot obtain a dependent’s SSN, you can use the date of birth instead. You may need to prove to the IRS that you made at least three attempts to obtain the dependent’s SSN.
If your organization does not have all the necessary information to complete these forms, it’s time to act fast! Contact your Fall River Client Manager with any questions and to make sure you feel comfortable with the process – we’re here to help!
Read 1581 times Last modified on Tuesday, 19 December 2017 12:33