Question: If a company did not have 50 or more full time employees, does it still need to report to the IRS or send 1095-C forms to employees?
Answer: If a company is certain that it did not employee 50 or more full time or full time equivalent employees for 120 days or more during the 2015 calendar year, then it is not an ALE subject to the ACA mandate, and it can claim the seasonal exemption.
If the company is not certain of this, it can use the Full Time Employee Count Report in either the Datatech Payroll or HRM programs to determine its status. If it is determined that it is an ALE, then it is subject to the mandate to report and print 1095-C forms for those employees that worked full time at least one month during the year. All other employees would not need to receive a 1095-C. However, even though the company must report 1095-C information, if it had less than 100 full time or full time equivalent employees, then it can claim transitional relief for 2015, and it did not have to provide Health Insurance during 2015. Starting January 1, 2016 and going forward, it does have to begin providing Health Insurance coverage to full time and full time equivalent employees.