What to do about ACA Reporting

I have been advising employers to wait until February 1, 2017 before starting work on the 2016 1094 and 1095 forms. My hope was that, based upon all of the campaign rhetoric, the ACA reporting obligations would either be further delayed or repealed during the first couple of weeks of the Trump administration.

President Trump did issue an executive order on January 20, 2017 instructing all federal government agencies “to waive, defer, grant exemptions from, or delay the implementation of any provision or requirement” of the ACA. Unfortunately, as of February 1, a lengthy delay or repeal of the reporting requirements has not occurred.

I now believe that employers need to start working on the 1094 and 1095 forms to meet the applicable filing and distribution deadlines.  The deadline to file 1094-B, 1095-B, 1095-C and 1095-C (as applicable) with the IRS is February 28, 2017, or March 31, 2017 if filing electronically.  Form 1095-B or Form 1095-C (as applicable) must be distributed to employees by March 2, 2017.

About Jim Hamilton

I am an employee benefits partner with Bose McKinney & Evans LLP. My broad-based practice covers health and welfare arrangements, insurance, executive compensation and federal and state taxation. Among other areas, I have specific experience with PPACA, HIPAA, COBRA, ERISA and numerous other state and federal laws affecting employee benefit plans.
This entry was posted in Patient Protection and Affordable Care Act and tagged , , , , . Bookmark the permalink.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s