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Employers who participate in the State Health Plan have certain requirements under the Affordable Care Act (ACA). Employers must provide subscribers with proof of health coverage, and forms must be issued to subscribers by March 3, 2025.
The due date for filing 2024 returns with the IRS is February 28, 2025, for paper filers (less than 10 returns) and March 31, 2025, for electronic filers. Instructions for filing electronically are available on the IRS website.
Which forms to issue
Employers with fewer than 50 employees
- Issue IRS Form 1095-B to any active employees enrolled in health coverage at any time during 2024.
Employers with 50 or more employees
- Issue IRS Form 1095-C to any active employees offered health coverage at any time during 2024.
All employers except members of the State Applicable Large Employer (ALE) group
- Issue IRS Form 1095-B to any non-Medicare retirees or COBRA subscribers enrolled in health coverage at any time during 2024.
PEBA will issue Form 1095-B to any non-Medicare retirees or COBRA subscribers for members of the State ALE group. PEBA will also issue Form 1095-B for employers who are able to designate PEBA as their Designated Governmental Entity (DGE).
Employers must also submit Forms 1094-B or 1094-C to the IRS by February 28, 2025, if filing by paper (less than 10 returns) or March 31, 2025, if filing electronically.
ACA files on EBS
To assist employers with their reporting requirements, PEBA will provide them with a file that contains information about their employees and dependents who were enrolled in health coverage at any time during 2024. PEBA posted ACA files for employers who are not members of the State ALE on Friday, December 6, 2024, under the Enrollment reports tab in EBS. Updated files will be posted each Friday through January 2025.
The files are fixed width, and each field (except GROUP) is delimited by a tilde (~) in the first position. There are no leading blanks. You will be able to access the files using either delimited or fixed-width methods. To ease importing, the files do not have headings. Headings can be found at peba.sc.gov/aca.
The files can easily be converted to an Excel format. Detailed instructions on how to convert the text file to an Excel file can be found at peba.sc.gov/aca.
Helpful tips
- Employers who designated PEBA as their DGE will see a file for their active employees only.
- Employers who did not designate PEBA as their DGE might find two files: one for active employees and one for non-Medicare retirees and COBRA subscribers.
- Employers who have employees who are covering dependents due to a National Medical Support Notice might also see a separate file for those employees (1095-CN).
- The file to use for all active employees is titled “1095-C.” If you are a small employer with fewer than 50 employees and are issuing Form 1095-B to your active employees, you will still use this file to retrieve the information needed.
- PEBA will issue forms for all eligible survivors.
- All coverage information for an employee who was enrolled in health coverage and retired during 2024 should be reported by the previous employer on the appropriate 1095 form. PEBA will include any retiree coverage information, along with the active coverage, on the file. The employee should not be issued two forms.
- All coverage information for an employee who was enrolled in health coverage, left employment and enrolled in COBRA in 2024 should be reported by the previous employer on the appropriate 1095 form. PEBA will include any COBRA coverage information, along with the active coverage information, on the file. The employee should not be issued two forms.
- Medicare-eligible retirees will not be included on the 1095-B file. Employers are not required to report coverage for Medicare-eligible retirees. If a retiree became Medicare eligible during 2024, only the months they were covered before they became Medicare eligible will be reflected on the file. For example, if a retiree turned 65 in May, the 1095-B file will reflect coverage information only for January through April, even though they were still enrolled in retiree coverage. Any retiree dependents will reflect the coverage, too.
- When completing Form 1095-B, remember the State Health Plan is employer-sponsored coverage (Line 8 – Origin of the Policy). Therefore, per the IRS instructions, Part II should be left blank. Employer information should go in Part III, as you are the sponsor of a self-insured employer plan.
Additional ACA resources are available at peba.sc.gov/aca. For questions, email PEBA Customer Service at peba.sc.gov/contact-employer or Denise Hunter at dhunter@peba.sc.gov.
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