Are YOU an applicable Large Employer under ACA?

Are YOU an applicable Large Employer under ACA?

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This is a reminder that all ALE’s (Applicable Large Employer’s) must comply with the “Pay or Play” rules outlined in the Affordable Care Act (ACA) beginning January 1, 2016 and the IRS Code Section 6056 reporting beginning in 2016, for the 2015 calendar year.

‘ALE’ is defined as an Employer who has an average of 50 or more Full Time Equivalent (FTE) employees during the prior calendar year (please see “Are you an ALE” ).

Note: A full time equivalent employee (FTE) is a combination of employees, each of whom individually is not a full time employee (has fewer than 30 hours of service per week) but who, in combination, are equivalent to a full time employee.

Pay or Play Rules for Groups 50-99 go into effect January 1, 2016
The Employer shared responsibility provision of the Affordable Care Act (ACA) requires ALE’s to offer affordable, minimum health insurance coverage to their full time employees, or pay a penalty. ALEs will face penalties if one or more of their full-time employees obtain a premium tax credit or cost-sharing reduction through an Exchange. An individual may be eligible for a premium tax credit or cost-sharing reduction either because the ALE does not offer coverage, or the ALE offers coverage that is either not “affordable” or does not provide “minimum value.”

IRS Code 6056 Reporting for 2015
The Individual shared responsibility provision of the ACA states that every person must have basic health insurance, also referred to as Minimum Essential Coverage (MEC), or face a penalty.

In order for the IRS to confirm if ALE’s and Individuals offer and/or has Minimal Essential Coverage (MEC), the IRS requires those who provide MEC to comply with IRS Code Section 6056 reporting.


• ALE’s that offer MEC coverage


• MEC data to the IRS using Form 1095-C
• MEC statements to workers using Form 1094-B (Insurance Carriers will supply these directly to members)
o Due to members by January 31 (like W-2 or 1099)


• IRS reporting is due starting in 2016 for 2015 coverage year and every year there after
o February 28 due for paper filing
o March 31 due for electronic filing
 Mandatory electronic filing for groups over 250
o For the 2016 filing, the IRS has stated that they will not penalize employers who file, but have missing or inaccurate data.

Please click here to view the IRS guidelines on the 6056 Reporting. The tracking of the MEC data should be done through your payroll administrator, so please contact them to be sure they are tracking this data for you, if you haven’t already.

Although we know how many employees are covered under your group benefit plan, that may not represent how many actual employees you have. If you have more than 50 employees on payroll (part time, full time, etc.) please contact us so we can help determine if you need to comply with these guidelines.

Keep in mind that Corporate Strategies, Inc. now offers payroll services, and our low fees include MEC tracking. If you would like to learn more about our Payroll and/or HR services, please contact your Account Executive or Account Manager.

We strive to keep you informed of the ever-changing world of healthcare reform and relative legislation, and are always available to address any questions or concerns you may have.
We welcome your feedback, so please contact any one of us at any time!