Employer Shared Responsibility Provision – ACA Reporting For 2015 And Beyond


Please consult the resources below to determine your status and filing requirements. These sites also have examples and further illustrations and discussion.

First: Are you an Applicable Large Employer (ALE)?

Most churches in the West Ohio Conference are NOT applicable large employers (ALE). However, the determination is made on a case-by-case basis, and you should consult the above resources to verify your church’s status. If you are not an ALE, the IRS employer reporting provisions do not apply to you. You do not need to read the remainder of this article.

An ALE has at least 50 full-time employees (FTE) or full-time equivalent employees (FTEE) based on the prior year actual hours worked. If you are not an ALE, you may or may not offer health insurance at your discretion. These IRS employer reporting provisions do NOT apply to you.

Second: Do you qualify for Transition Relief for 2015?

If you are an ALE and qualify for Transition Relief, you must file Form 1094-C to claim it! It is not enough to qualify, you must submit the completed form to notify the IRS that you qualify for the Transition Relief.  Even if you qualify for transition relief, you must still file Forms 1094-C and 1095-C.

ALE Employer Reporting Responsibilities

The table below indicates which organization is responsible for preparing and issuing the indicated forms (if you are subject to reporting requirements):

If your church is not an ALE, the table below does not apply to you!

FormsCalendar 2015(provided in Jan 2016)Calendar 2016(provided in Jan 2017)
Forms to Employees/IRS
1095-An/a for Churchesn/a for Churches
1095-B Health CoverageThis form is an individual’s “Proof of Health Insurance” for tax purposes if they participate in an employer plan.Aetna*West Ohio Conference*
1095-CThis is an employer’s notification to the IRS and employee that health insurance was offered. Generally, any employee who was full time during any month of the year or any employee who participates in the health insurance plan will receive this form, even if (s)he does not elect coverage.Church (employer) Church (employer)
Transmittal forms to IRS only
1094-An/a for Churchesn/a for Churches
1094-BAetna*West Ohio Conference*
1094-CChurch (employer)Church (employer)

*Aetna and the West Ohio Conference will provide the Forms 1094-B and 1095-B forms for all participants of the West Ohio Conference Flexible Benefits Plan. If you have a different employer health insurance provider, you must coordinate preparation of Forms 1094-B and 1095-B with your provider.

Due dates

  • On December 30, 2015, the IRS extended the deadlines for 2015 reporting. Forms 1095-B and 1095-C are due to be furnished by March 31 instead of January 31. Forms 1094-B and 1094-C are due to the IRS by May 31 (or June 30 if filing electronically).
  • For future years, forms are due to employees by January 31 (or next business day).
  • After 2015 reporting, copies of the forms along with the respective transmittal forms are due to the IRS by February 28. (March 31 if filing electronically.)

Frequently Asked Questions

Q: For purposes of ACA, who is the employer for appointed UMC clergy?

The local church to which the clergy is appointed is considered the clergy’s employer for ACA purposes.

Q: What if a lay employee is eligible for health insurance but opts out of coverage?

The best practice is to have a written record of the employee’s election not to participate in the plan. In this case, the employee will still receive a 1095-C form but no 1095-B form.