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The EIN for the ALE member (Cabinet level Departments, independent agencies, boards and commissions that make up the ALE).
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OPM is facilitating compliance with section 6056 reporting requirements by working with the shared service centers, Internal Revenue Service, OMB and agencies. OPM is sharing guidance related to the FEHB program needed for section 6056 reporting.
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An applicable large employer (ALE) is an employer with an average of at least 50 full-time employees.
An applicable large employer may be a single entity or may consist of a group of related entities. If there is a group of related entities, these are referred to as ALE members. For more information on these definitions and other IRS related questions, see the
IRS Questions and Answers on section 6056 reporting.
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To ease compliance with IRC section 6056, OPM is providing a definition of the ALE and ALE member. The ALE is the group of civilian, non-Postal, executive agencies that are permitted by statute to participate in the FEHB Program. The ALE members are Cabinet level Departments, independent agencies, boards and commissions that make up the ALE. It is the responsibility of government entities outside the OPM defined ALE to determine whether they are ALEs and responsible for reporting.
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The ALE member must file a separate
Form 1095-C for each of its full-time employees and a transmittal on
Form 1094-C for all of the returns filed for a given calendar year.
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The designation letter should be signed by the person who has authority to make payroll decisions on behalf of your agency. This could be the Chief Human Capital Officer or the contracting officer overseeing the contract with your payroll provider and who may be located in the Human Resources Department or your Chief Financial Officer Department.
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OPM provided a
designation form which can be used to designate a shared service center to report on behalf of the agency. This information will be used for purposes of reporting in 2016.
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An ALE member generally must furnish to each full-time employee a written statement showing health insurance information about the employee. The ALE member may use a copy of the Form 1095-C to furnish this information to the employee.
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The Affordable Care Act (ACA) added section 6056 to the IRC, which requires applicable large employers to file information returns with the IRS and provide statements to their full-time employees about the health insurance coverage the employers offered. The IRS uses the information provided on the information returns to administer the employer shared responsibility provisions of IRC section 4980H.
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Applicable large employers are required to file information returns with the Internal Revenue Service (IRS) and provide statements to their full-time employees about the health insurance coverage the employers offered.
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Health and Human Services is the ALE member since it is the Cabinet level Department.
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Section 6056 requirements are effective for coverage offered in 2015. An ALE member must file information returns with the IRS and furnish statements to employees beginning in early 2016. These reporting requirements must be met annually.
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No, ALE members are required to report information on all full-time employees within the meaning of full-time employee defined under IRC section 4980H. For more information on the identification of full time employees for purposes of the Employer Shared Responsibility provisions, see
Question 15 from the IRS Questions and Answers.
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No, the agency is not required to designate the shared service center to report on the agency’s behalf. The agency may also do their own reporting.
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No, the IRS requires all employers with 50 or more full-time employees to follow reporting requirements.
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If your agency designates your shared service centers to report on your behalf, you will need to provide all necessary information to your shared service center that they do not already have. There may be some additional information that needs to be certified to your shared service center related to the offer of coverage.
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No, the agency is not required use the designation form. However, it is strongly encouraged. The designation is drafted based on requirements in the IRC section 6056 regulations. See 26 USC section 6056(e) and accompanying
regulations for more information on designating a governmental entity.
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Agencies are not required to list dependents on the IRS Form 1095-C for enrollees that have FEHB coverage. Enrollees may receive dependent information from their FEHB carrier, but not from their employer.
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It is an employing agency’s responsibility to verify and answer questions about an employee’s data on the IRS Form 1095-C. The employing agency must then work with its payroll provider to make appropriate corrections to forms. Please do not advise the enrollee to call OPM or the IRS because OPM or IRS do not have information about specific employee forms.
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