ACA Reporting Deadline Reminders

The new year started off with quite a bang as SCOTUS made their ruling regarding the vaccine or test mandate, COVID at home test kits coverage requirements kicked in and more COVID developments dominated the headlines.

This article serves as a reminder for ACA Reporting Deadlines imposed on Applicable Large Employers (ALEs).

 

 

 

There are two components to ACA reporting requirements.

      1. ALEs must furnish a 1095-C to full-time employees by March 2, 2022
      2. ALEs must report 1094C and 1095C information to the IRS by March 31, 2022 (if mailing, the deadline is February 28, 2022)

There is also state-level reporting of such forms that were introduced via certain state individual coverage mandates:

CA, RI and MA require ALEs to furnish 1095C to its residents by January 31, 2022, which does not coincide with the federal deadline. This requirement introduced confusion in prior years which seemed to have led to some leniency from the applicable states to not impose penalties for failure to meet the deadline. In fact, as of this writing, the CA Franchise Tax Board (FTB) has posted that it will not impose penalties on employers who fail to provide the forms by the January 31, 2022 deadline.

Special note: CA, RI, MA, NJ and DC impose reporting requirements onto ALEs that employ workers in the applicable states.

CA, RI, MA, and NJ require certain group health plans to submit state-level reporting by March 31, 2022. However, CA applies an automatic extension and will not apply penalties for returns filed by May 31, 2022.

For more information regarding state level reporting for employers with CA residents, click here.

For more information regarding state level reporting for employers with RI, NJ, MA, or DC, please contact your Bolton representative.

Summary:

ALEs offering medical coverage to CA, RI or MA residents should ensure 1095-C statements are provided to employees by the CA reporting deadline of January 31, 2022.

Special note: The CA Franchise Tax Board (FTB) has posted that it will not impose penalties on employers who fail to provide the forms by the January 31, 2022 deadline.

Additionally, employers that sponsor self-insured medical plans or MECs will need to comply with the applicable state reporting mandate by the state specific deadlines.

 

While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept  liability  for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting or other professional advice or services. Readers should always seek professional advice before entering into any commitments.


About Michelle Cammayo

Michelle Cammayo has more than 13 years of Employee Benefits experience specializing in all lines of health and welfare benefits. Today, Michelle works closely with clients and partners to provide guidance in areas of the law including ERISA, HIPAA, COBRA, FMLA and PPACA. She also oversees the Compliance Department at Bolton & Company to ensure we are helping our clients manage and eliminate risk with regards to employee benefit compliance.

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