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ACA Reporting Requirements for Carriers and Employers (Part 19 of 24): Terminations, Changes in Status and Service Breaks Under the Look-Back Measurement Method
Mintz LevinLink to more items from this source
[Guidance Overview]
Dec. 3, 2015

"While the consequences of failing to offer coverage during a stability period to an employee who has qualified as full-time are not specified in any formal guidance, representatives of the Treasury Department and IRS, in non-binding, off-the-record comments, have asserted that the benefit of the look-back measurement method is retroactively unavailable with respect to affected employees, thereby requiring an amended Form 1094-C and 1095-C for the prior year. In addition, depending on the facts-and-circumstances, there might be penalties for filing an inaccurate Form[.]"

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