Having spent several months compiling the data required for its Applicable Large Employer (ALE) clients, TriCore is among the first HR outsourcing companies to have developed programs and routines to help employers to accurately complete and submit IRS Forms 1094-C and 1095-C. TriCore has observed that (a) most ALEs have not maintained the records needed to accurately complete the forms, and (b) most insurance brokers do not know how to help them. For those TriCore clients for whom TriCore has served as both payroll administrator and benefits broker, the process was at least possible, because much of the required data resided in TriCore’s integrated payroll & benefits administration systems. For those clients using third-party insurance brokers, the process was substantially more difficult and laborious and, in some cases, impossible.
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Many affected employers have discovered that they simply do not have the information needed to satisfy the very thorough and complicated reporting requirements. For example, Form 1095-C (Employer-Provided Health Insurance Offer and Coverage), which must be delivered to every employee of an ALE, requires that a certain code be entered for every month of the year, indicating whether the employee was eligible for coverage and whether Minimum Essential Coverage was offered and to whom (i.e. employee only, employee and spouse, employee and dependents, etc.). In many cases, the employer has not kept records of individual employee eligibility, and in many other cases neither the employer nor the broker has kept records of offers of coverage to employees and whether or not the employee declined the offer.
Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) tells the IRS if the ALE offered Minimum Essential Coverage, and to whom. Again, if the employer and broker failed to keep records of offers and declinations, it may be impossible to accurately complete the form.
Fortunately for its clients, TriCore’s programs facilitate the maintenance of the information needed to complete both forms. To learn more about our human capital management solutions, call 609-918-2668 or contact us.