IRS Reporting and Measurement Periods
Heads Up – Changes for ACA 2018 - IRS Reporting Forms 1094 and 1095
Effective January 1, 2018 the VEHI Health Program became formally self-insured. This requires a change in the annual ACA IRS Reporting process, beginning with the 2018 forms submitted to the IRS in early 2019. Below is a summary of the changes and resources (see link below) available to support the completion of the ACA 1094 and 1095 reporting requirements. Please contact Laura Soares (firstname.lastname@example.org or (802) 223-5040 extension 208) or Angela Tremblay (email@example.com or (802) 223-5040 extension 230) with any questions.
Large Districts – also known as applicable large employers or ALEs with 50 or more full-time equivalents (FTE)
- Employers will continue to complete Parts I and II for forms 1095-C as in prior years.
- Employers will ALSO complete Part III of 1095-C, checking the self-insured box at the top of Part II.
- Part III provides information to the IRS on the individual mandate – indicating what months in the calendar year the employee, their dependents and any COBRA participants had health coverage.
- This section will no longer be completed by BCBSVT and filed/mailed separately.
- Employers will continue to submit forms 1094-C and 1095-C (now with Parts I, II and III completed) to the IRS and provide a copy to employees.
- Employers will ALSO provide COBRA participants who were not active at any time during 2018 with a copy of form 1095-C.
Small Districts - non-ALEs with fewer than 50 FTEs enrolled in health coverage
- Employers need to provide information to the IRS on the individual mandate – indicating what months in the calendar year the employee, their dependents and any COBRA participants had health coverage.
- This information will no longer be provided by BCBSVT on behalf of the employer.
- Employers will complete 1094-B and 1095-B forms as self-insured employers and submit this information to the IRS.
- Employers will ALSO provide employees and any COBRA participants who were not active at any time during 2018 with a copy of form 1095-B.
Please note – if your central office has never completed the IRS Reporting for any district, VEHI will be reaching out to you regarding an option for additional support. This applies to many private schools, tech centers and associations, as well as a few very small supervisory unions. Feel free to reach out to Angela Tremblay if you are not sure if this applies to you.