Bah Humbug! The Three Ghosts of PPACA Reporting: Past, Present, and Future


It’s the most wonderful time of the year!  It’s holiday shopping, putting up decorations, trying to make sure you’re on the nice list (unless you’re Steve), and...reading the IRS’s instructions on filling out forms 1094-C and 1095-C for PPACA reporting?  Okay, maybe not everyone, but school business officials are already dreading the 3 days after Christmas and New Year’s when they’ll scramble to get as much of this work done as they can before staff return and begin demanding their W2’s in early January...

If you’re an administrator, do us a favor.  Hit “forward” right now and send this to your school’s business official(s) before you keep reading.  

Quick refresher on PPACA reporting: all “applicable large employers” (ALE) are required to make certain reports to their employees and to the IRS regarding offers of health insurance and the “affordability” of those offers, among other things.  

For those lucky enough to have avoided reporting because you are a “small employer,” keep in mind the determination of ALE status is an annual requirement.  If you have not refigured your “ALE number” for 2018 and thus whether you need to report, now’s the time. (Remember that your 2018 status is based on calendar year 2017 data, and only the federal government can make counting to 50 a task that requires legal advice — for the IRS’s explanation on calculating your ALE number click here.). If you’re still under 50 after going through the strange IRS calculations for ALE number and do not have a self-insured health care plan, it’s time to bust out the egg nog because you likely don’t have to report for 2018!

For those who are ALE’s and aren’t so lucky, you’ll remember forms 1094-C and 1095-C.  You may also remember some of the trickier considerations for reporting, like accounting for “cash in lieu” and the “safe harbors” for classified staff members who do not get all premiums paid by the district or ESU.  Like a foreign language, now’s the time to relearn how to “speak PPACA” so you’re ready to hi your reporting deadlines in early 2019. They are similar to past years:

January 31, 2019: individual 1095-C forms due to all “full-time” employees

February 28, 2019: 1094-C and 1095-C’s due to IRS if filing on paper

March 31, 2019: 1094-C and 1095-C’s due to IRS if filing electronically

Of note, there are other significant PPACA developments to learn about in terms of 2018 reporting and how PPACA will actually function in 2019 and beyond. For example, beginning in 2019 the “individual mandate” goes away, and some studies estimate that 4 million people will leave the Marketplace next year.  Because an employee obtaining insurance through the Marketplace is a component of the tax penalty calculations, that could mean changes in your board’s prior assessments of PPACA compliance and insurance offers. Similarly, the “affordability” threshold—which establishes the percentage of household income an employee can be required to pay toward your cheapest single insurance plan—actually went down (from 9.69% back to 9.56%) for 2018, marking the first drop in years.

As a school or ESU, you should be thinking through these things now, while the 2018 reporting is fresh in your mind over the next few weeks.  KSB’s annual PPACA reporting webinar will be held December 18, and you can register or purchase the recording and materials here:

If you have questions about your reporting obligations or any other area of PPACA compliance, you should consult with your school or ESU’s attorney or contact Karen, Steve, Bobby, Coady, or Mandy.