ACA reporting deadlines and EEO-1 dates you should know

Ready or not, it’s almost time for the next wave of ACA and EEOC reporting.

While you should be tracking employee data on an ongoing basis, now is the time to pay even closer attention to the data you’ll need to ensure ACA and EEO-1 compliance, and begin laying out a timeline to make sure you hit all the filing deadlines you need to meet. As we enter the last quarter of 2017, it’s time to look ahead to the deadlines and dates that you’ll need to meet to complete your various compliance filings without fines.

To ensure you’re prepared, we’ve put together a list of some of the most important upcoming deadlines for ACA and EEO-1 compliance.

ACA dates and deadlines

Early to mid-January: All data should be collected and uploaded for ACA reporting.

Getting your data in order is absolutely crucial to successful ACA filing. While there’s no official deadline for this from the IRS, it’s recommended that you get your data squared away as soon as possible. For most employers, that will mean a week or two after the end of the year, when the last pay period has been fully processed, and the last week’s hourly information can be properly recorded. If you’re keeping up with your employees’ census, hourly tracking, and benefits data monthly (as you should), this process should be simple. However, if you’re waiting for the end of the year to go back and fix all your mistakes, you could be in for a stressful few weeks.

January 31: Furnish 1095-C (and B) to employees.

The first official step to compliance is furnishing your employees with their 1095-Cs (and potentially 1095-Bs, if you’re self-funded). Your 1095-Cs will cover important milestones such as when or if employees were provided an offer of health insurance, the safe harbors used to make sure a health plan was affordable, and demographic information for individual employees. Make sure to send these forms out by the end of January to successfully move forward with compliance, and then begin the corrections process, which should be completed by the filing deadline.  Remember, you cannot just hand these forms to employees.  The IRS has a specific format, process and associated information for 1095-Cs.

February 28: Paper filing of 1094-C and 1095-C.

While paper filing for ACA compliance is nearly impossible and definitely inadvisable, companies with fewer than 250 employees are allowed to submit their 1094-Cs and 1095-Cs to the IRS on paper. This tends to contribute to more mistakes, a longer back-and-forth period if those mistakes cause a rejection of your forms, and overall, more complications. But if you’re determined to submit on paper, make sure your documents are postmarked by February 28.

March 31: Online filing of 1094-C and 1095-C.

This is the date most employers want to keep in mind. For all applicable large employers (ALEs) with over 250 employees, online filing is mandatory. For those with fewer employees, it’s still recommended as an easier course of action. While the IRS has extended the deadline for the past three years, don’t expect the same flexibility in 2018. Additionally, late filing has been one of the few fines that the IRS was set to collect on despite the “good faith effort” exceptions of the past few years. Even if noncompliance fines are pushed back again (this isn’t expected), late filing can still earn you a major penalty.

EEO-1 dates and deadlines

October, November, or December: Collect a workforce snapshot of salary data.

EEO-1 data depends on a workforce snapshot of a pay period from the end of the year. That means that you should be picking a pay period in October, November, or December, and be making arrangements to collect and properly store your data from one of these months. It’s always advisable to get your compliance data in order earlier, but if October doesn’t work for you, make sure you’re prepared going into November or December.

Late January: EEO-1 Survey opens.

If you submitted an EEO-1 form last year, you’ll receive a letter of notification letting you know when you can start submitting data to the Joint Reporting Committee. This typically happens two months before the submission deadline, although there is no firm date. If you didn’t file EEO-1 data in the last survey cycle, you can check the EEOC’s EEO-1 Survey website to find out when the survey opens, or follow us on Twitter or through our newsletters to get up-to-date information on the survey opening.

January 15 to March 1: Review self-reported employee data.

The EEO-1 report is special in that it requires some employee data to be self-reported. In order to ensure your employees are accurately and punctually filling out this information, establish company guidelines to complete their portion between January 15 and March 31, giving yourself a bit of a cushion to review the data and submit it before the submission deadline.

March 31: EEO-1 submission to EEOC.

Final submission for the EEO-1 requirement is due on March 31—the same day as ACA online filing. Just like the ACA, late filing can bring about fines. Make sure to have all your data in order before then, including the workforce snapshot from the fourth quarter of 2017, and the self-reported race and gender information from your employees.

Stick to the schedule

With the reporting deadlines for both the ACA and EEO-1 regulations falling on the same day, it’s likely to be a stressful couple of months. Keep this list of dates handy, and take the proper steps toward data collection and submission now, so that you’re not rushing when these deadlines roll around.