ACA Reporting Adviser

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, general questions on reporting requirements will be answered. For detailed information on form completion, contact your tax adviser, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to aca@msec.org. The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).

  1. When should an employee who has a change in employment status be offered health care benefits?
  • Change from seasonal or part time to full time
    • Follow your plan’s rules for offering benefits to full time employees
  • Change from seasonal to part time
    • If the seasonal employee is currently enrolled in a health plan for a stability period, the employee may remain covered through the end of that stability period. Thereafter, follow your plan’s rule for offering benefits to part-time employees.
    • If the seasonal employee is not covered, follow your plan’s rule for offering benefits to part time employees

In either case, if you use the look-back method of counting hours, continue to track hours worked during each measurement period.

  • Change from full-time to part-time
    • If the full-time employee met the measurement-period-hours requirement for benefits to be offered during the current stability period and the employee enrolled in coverage, continue offering benefits until the end of the stability period. If not, follow your plan’s rule for offering benefits to part-time employees. COBRA may need to be offered at the end of the stability period if coverage is lost at that time due to the reduction in hours. Continue to track hours worked during each measurement period.