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Month by Month, Employers Must Track Employees in 2015 for Required Reporting under ACA Rules
Frost Brown Todd LLCLink to more items from this source
[Guidance Overview]
Jan. 12, 2015

"Even though the penalties only apply if there are 100 or more employees for 2015, employers with 50 or more full-time equivalent employees are required to report for 2015. Also note this reporting is required even if the employer does not maintain any health plan.... For the pay or play reporting, each [applicable large employer (ALE)] must file a Form 1094C reporting the number of its full-time employees (averaging 30 hours) and total employees for each calendar month, whether the ALE is in a 'aggregated' (controlled) group, a listing of the name and EIN of the top 30 other entities in the controlled group (ranked by number of full-time employees), and any special transition rules being used for pay or play penalties. ALE's must also file a 1095C for each employee who was a full-time employee during any calendar month of the year. The 1095C includes the employee's name, address and SSN, and month by month reporting of whether coverage was offered to the employee, spouse and dependents, the lowest premium for employee only coverage, and identification of the safe-harbor used to determine affordability."

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