ACA and Healthcare Reform

Ballard Spahr LLP: New Guidance on Affordable Care Act Reporting Requirements

By Edward I. Leeds

The Internal Revenue Service has issued two lengthy sets of questions and answers on the requirement under the Affordable Care Act that employers report on their compliance with the employer mandate and employees' qualification for exchange subsidies. The new guidance is divided into general information about the reporting rules and information about completing the actual forms. The questions and answers largely confirm guidance previously issued in forms, instructions, regulations, and a prior set of Qs & As, but contain useful details on several matters, such as:

  • The extent to which employers with no full-time employees need to meet reporting requirements,
  • The absence of an obligation to provide Form 1095-C to an employee on request, and
  • The treatment of COBRA participants in different situations.

Employers may find this new guidance useful as they prepare to meet the new reporting requirements that will begin to apply in the first quarter of 2016.

If you have questions about the coverage of preventive care products and services, contact Edward I. Leeds, counsel in Ballard Spahr’s Employee Benefits and Executive Compensation (EBEC) Group, at 215.864.8419 or leeds@ballardspahr.com; Jean C. Hemphill, practice leader of Ballard Spahr’s Health Care Group, at 215.864.8539 or hemphill@ballardspahr.com; Brian M. Pinheiro, practice leader of Ballard Spahr’s EBEC Group, at 215.864.8511 or pinheiro@ballardspahr.com; Diane A. Thompson, partner in Ballard Spahr’s EBEC Group, at 424.204.4334 or thompsonda@ballardspahr.com; or the member of the Employee Benefits and Executive Compensation practice group with whom you regularly work.


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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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