Since 2015, employers have been subject to the Affordable Care Act (ACA) information reporting requirements and penalties. For the 2015 reporting year, the IRS extended the deadlines and gave employers a few extra months to provide these forms to their employees and to file them with the IRS. However, this transition relief was not extended to the 2017 deadlines for the 2016 reporting year. As a result, reporting deadlines for filings in 2017 are months earlier as compared to 2016.

Also ending in 2016 is the Section 4980H Transition Relief. This relief exempted medium-sized employers (those with 50 to 99 full-time employees or full-time employee equivalents) from penalties for the 2015 plan year if certain conditions were met. Large employers (those with 100 or more full-time employees including full-time employee equivalents) were also treated as offering coverage to all of their full-time employees for a month in which they offered coverage to just 70 percent of those employees for the 2015 plan year.

As this transition relief has ended for the 2016 plan year, medium and large employers can be subject to penalties if they do not offer coverage to at least 95 percent of their full-time employees under the ACA’s shared responsibility provisions.