At the end of 2014, your ministry looked at IRS guidelines to determine whether offering health care was a requirement. The coverage you did or did not offer in 2015 will be the basis for IRS reports that are due in early 2016.
Is your ministry required to report?
The Internal Revenue Service identified certain employers who must offer minimum essential health coverage to their employees—referred to sometimes as the employer mandate or pay or play provisions.
The following employers qualify to report:
- Applicable Large Employer (ALE). An ALE is an employer with 50 or more full-time and full-time equivalent employees (FTE) as determined in 2014. ALEs will need to file an annual information return reporting what, if any, health insurance they offered employees. The reporting requirements apply to:
- All ALEs starting in 2015.
- Employers with special circumstances that qualified for transition relief from employer shared responsibility payments for 2015.
- Controlled group. A controlled group is a combination of two or more corporations under common control. Ministries with a common owner or that are otherwise related, potentially may need to be combined and treated as a single employer for determining ALE status. You should speak with your legal or tax advisor to determine if this may apply to you.
- Examples of a controlled group or affiliated service group:
- A church that runs a separate day care and both are controlled by the same board.
- A church that plants, and maintains control of, other ministries.
- Example of how controlled group employees combine:
- Ministry A and B both have 30 full-time employees, so separately, they would not have to provide health care insurance. However, Ministry A controls Ministry B, and together are considered a controlled group with a combined 60 full-time employees. Both employers may be considered an ALE and Ministry A would need to report on behalf of both ministries.
- Self-Insured Ministries. Certain reporting requirements also apply to employers that sponsor self-insured coverage, even if the employer is not an ALE.
Which forms are required?
These same employers are have information reporting responsibilities. Ministries subject to the Affordable Care Act (ACA) shared responsibility provisions must file one the following forms:
- Authoritative transmittal form
- Form(s) 1094-C
- Form(s) 1095-C, or a substitute form, for each full-time employee for each month of the calendar year. Generally, the employer is required to furnish a copy of the Form 1095-C to the employee.
An employer that offers health coverage through an employer-sponsored self-insured health plan must complete Form 1095-C, Parts I, II and III, for any employee who enrolls in the health coverage, whether or not the employee is a full-time employee for any month of the calendar year. You can find more information about the required forms, including links, here.
Contact your ministry’s legal or tax advisors and medical insurance provider for additional guidance.
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The information in this article is intended to be helpful, but it does not constitute legal advice and is not a substitute for the advice from a licensed attorney in your area. We strongly encourage you to regularly consult with a local attorney as part of your risk management program.
