Whereas employers traditionally had to provide quarterly and yearly summaries for IRS reporting on their workforce, they now have to make sure they can get at their data for intricate breakdowns in monthly reports. Because payroll data is the body of information that sheds light on how employers will comply with these new and exacting reporting requirements, ACA changes to the Internal Revenue Code are transforming the work life of anyone who has anything to do with payroll processing.
In the past, most regulatory reporting for payroll activity centered on dollars – not hours.
But population of IRS Form 1095-C (the complicated new form known as the ACA counterpart to a W-2) hinges on tracking hours of service – not just paid hours of work.
This distinction is important because, to determine which employees are full-time – and thereby eligible for health coverage, employers now need a tracking system that accounts for non-paid time on the job. The task, then, of figuring out which employees to give the 1095-C form to can be tougher than the printing of this challenging form itself.
Not only do employers have to report on which employees are eligible for offers of coverage, they also need to report on attributes of the health insurance offered: Does it meet ACA standards for quality? And in each eligible employee’s case, does it meet ACA standards of affordability?
Deadlines for getting Form 1095-C to employees and for filing its transmittal, Form 1094-C, with the IRS are in Q1 2016. Generation of these files has nothing to do with an employer’s pay or play strategy. If you are an applicable large employer, getting these forms out is a federal mandate.