As we approach Affordable Care Act (ACA) IRS reporting for 2016, Applicable Large Employers (“ALE Members”) are required to file an annual return (Form 1094-C) with the IRS and issue annual statements (Form 1095-C) to full-time employees about the health coverage offered to them. The IRS deadline for annual notice distribution to employees is January 31, 2017, and the employer annual return to the IRS is due by March 31, 2017, if electronically filed.
Whether an employer is an ALE is determined each calendar year, and it generally depends on the average size of an employer’s workforce during the prior year. If an employer has fewer than 50 full-time employees, including full-time equivalent employees, on average during the prior year, the employer is not an ALE for the current calendar year.
Note that an organization may also be an “ALE Member” if it is owned or controlled in common with one or more other organizations. If this scenario applies to you and the organizations that are under common ownership or control have 50 or more employees combined, you’re advised to consult with your legal counsel or tax advisor on whether or not your organization is an ALE member.
What do we need form you?
Please review your records to determine the average number of employees that you had in 2015. If you had an average of 50 or more employees or if it has been determined that you are an ALE Member per the above, please contact your HR Business Partner to advise them of your ALE status. Your HR Business Partner will ensure that our system is updated so that ADP TotalSource can proceed with filing your Form 1094-C and issuing a Form 1095-C to your full-time employees with your approval.
Why can’t ADP TotalSource® confirm this for me?
ADP TotalSource maintains employment data for its clients’ employees. We do not maintain data for our clients’ related companies, if they are not our clients. We must, therefore, depend on our clients to confirm this for us. Also, if your company was not a TotalSource client in 2015, we are unable to confirm the average size of your workforce during that year.
In order to simplify the ACA for you and ensure that you are able to focus on what you do best, we are pleased to deliver insightful solutions using industry-leading tools and expert guidance! If you have additional questions, please contact your HR Business Partner.