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IRS Issues Updated Guidance on ACA Reporting Requirements for Large Employers
The Wagner Law GroupLink to more items from this source
[Guidance Overview]
June 5, 2015

"An [applicable large employer (ALE)] with no full-time employees for any month of the year is not obligated to report unless the ALE sponsors a self-insured health plan in which any employee, spouse, or dependent is actually enrolled. In that case, the ALE must still file Forms 1094-C and 1095-C even if it has no full-time employees.... The guidance provides examples demonstrating how reporting differs when an ALE reports for separate divisions and when ALEs are part of a controlled group.... The guidance confirms that ALEs may not use simplified statements for employees who actually enroll in the ALE's self-insured plan.... Forms 1095-C may be delivered to employees in any manner permitted for delivery of Forms W-2."

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