AFFORDABLE CARE ACT – 1094-C / 1095-C
Contact us for 1094-C & 1095-C completion parameters / assistance.
Applicable large employers (“ALEs”) may have expected that the Republican-led administration would limit or choose not to enforce the Employer Shared Responsibility Provision mandate of the Affordable Care Act (“ACA”). However, the recent failure in the Senate to pass legislation to repeal and replace the ACA means ALEs should:
- Prepare for calendar year 2017 Form 1094-C and 1095-C reporting. The Form 1095-C for calendar year 2017 will be due January 31, 2018 to ACA FTEs (full-time equivalent) and, for self-insured group health plans, any covered non-ACA FTEs. Filings to the IRS are expected electronically by April 2, 2018 (and, for those eligible, on paper by February 28, 2018).
- Continue to identify ACA FTEs using the appropriate measurement method (monthly or look-back) and manage offers and affordability of coverage. Understand any potential penalty liability that exists in your organization.
- Await updates from the IRS, including issuance of the final CY 2017 Forms and Instructions, likely in September or October.
2018 HSA LIMITS
The 2018 limits for HSAs have been released by the IRS in Revenue Procedure 2017-37.
Minimum Annual Deductibles
Minimum annual deductibles required for a plan to be considered a “high deductible health plan” – HDHP – will increase to $1,350 for single coverage and $2,700 for family coverage.
Out of Pocket Maximums
The maximum out of pocket maximums for HDHPs for 2018 will increase to $6,650 for single coverage and $13,300 for family coverage (2017 levels are $6,550 single/ $13,100 family).
Annual Individual Contribution Limit
The maximum permitted contribution to the HSA on behalf of an individual increases to $3,450 for an individual with single coverage and $6,900 for an individual with family coverage (2017 levels are $3,400 single/ $6,750 family).