The Affordable Care Act (ACA) reporting requirements are confusing and time consuming. It’s why last year, many employers outsourced their ACA reporting. Still, mistakes were made, and employers faced penalties.
Last week, we discussed some common ACA reporting mistakes, like employers not properly reporting full month versus partial month enrollment, improper reporting on Line 14 and incorrect completion of Part II on Form 1095-C. This week, learn 4 more ACA reporting blunders and find out how to avoid them for next year.
Affordable Care Act Reporting Mistakes to Avoid
Incorrect COBRA coding in reporting.
An offer of COBRA coverage made to a former employee upon termination of employment should be reported as a Series-1 code 1H (no offer of coverage) and must be entered for any month for which the offer of COBRA coverage applies. Do not enter code 2C in Line 16 for any month in which a terminated employee is enrolled in COBRA continuation coverage; instead enter code 2A.
An offer of COBRA continuation coverage that is made to an active employee (e.g., as a result of a reduction in hours resulting in the loss of eligibility for coverage under the plan) is reported in the same manner and using the same code as an offer of that type of coverage to any other active employee.
Reporting codes should reflect measurement method.
Employers are permitted to determine full-time status using either the monthly measurement method or the look-back/stability measurement method. While the measurement method is not required to be “declared” on the Form 1095-C, the coding necessarily reflects the employer’s choice. Employers should ensure that they are measuring hours in accordance with an IRS-approved method and that the 1095-Cs generated reflect that approach.
Failure to account for stability period for employees experiencing a reduction in hours.
Outside of very narrow circumstances involving a bona fide change in position, if the employee’s hours are reduced below 30 hours a week, the employee must remain benefit-eligible for the remainder of the stability period (for most employers, the rest of the calendar year).
Incorrect reporting for new hire full-timers under look-back/stability period method.
The application of the look-back measurement method to a new employee depends on the employer’s reasonable expectations of the status of the employee at the start date. Employees reasonably determined to be in a full-time position are not placed in an initial measurement period. Instead, their hours are determined on a month-by-month basis. An employer’s reasonable expectations are only applied during the initial measurement period and not during subsequent standard measurement periods where the determination of full-time is strictly made by hours of service in the prior measurement period.
Manage ACA Reporting Requirements with EPAY Systems
EPAY Systems provides seamless human capital management software and services to help you manage ACA requirements—with minimal effort! Our system can track compliance and generate the necessary reports, including 1094 and 1095 forms, affordability test, hours worked reports and more. We’ll monitor how your full-time-equivalent employees are trending, help you plan for future exposure and even file your forms and notices directly with the IRS. Want to learn more about how EPAY can help? Contact us to learn about our ACA Compliance and Reporting Package.