Now that you have completed your 2015 Form 1095-C reporting for all employees and are finalizing the 2015 Form 1094-C filings to the IRS, it is time to look at 2016 ACA compliance. The complete and partial transition relief that was available in 2015 is no longer available in 2016 so you need to make sure you are ready.
For your 2016 plan year (taking effect on the first day of your 2016 plan):
· The 2015 transition relief for Applicable Large Employers (“ALE”s) with 50-99 full-time employees/full-time equivalents is gone. All ALEs must comply with the ACA’s employer mandate requirements.
· For 2015, ALEs needed to offer health insurance coverage to at least 70% of their full-time employees. Starting in 2016, ALEs must offer ACA-compliant coverage to at least 95% of their full-time employees to avoid penalties.
· In 2015, for ALEs with 100 or more full-time employees, if the ALE did not offer coverage to its full-time employees, the per-employee penalty was calculated by reducing the first 80 full-time employees. For 2016, that reduction is dropped to 30 so only the first 30 will be deducted from the full-time count in calculating the penalties.
Now is the time to review your 2016 ACA compliance.