In 2018, the Internal Revenue Service (IRS) will require employers subject to the Affordable Care Act's (ACA) reporting requirements to prepare and file Form 1095-C on their employees.
For information on who is required to complete a Form 1095-C and guidance on how to complete it as an employer covered under a multiemployer health and welfare plan, please see SMACNA’s Guidance on Applicable Large Employers from 2015 when the requirement first went into effect.
Making clear these forms would be required in 2018, the IRS published final forms and instructions to help employers prepare for reporting on health coverage they offered to their employees in 2017. The IRS recently extended the deadline to file by 30 days. Forms must be distributed to employees and filed with the IRS by March 2, 2018.
In addition, the IRS extended transition relief from penalties under sections 6721 and 6722 to reporting entities that can show that they have made good faith efforts to comply with the information reporting requirements.
Below is a list of the final forms. Search Forms and Instructions on the IRS website, www.irs.gov.
Health and Welfare Funds’ separate reporting requirement
Employers should keep in mind that insurance companies and health and welfare funds have a separate reporting requirement. The health and welfare fund’s reporting will not satisfy the employer’s obligation to report.
Questions on reporting may be directed to Joye Blanscett in SMACNA’s Labor Relations Department at firstname.lastname@example.org.