Last week, BNSF made SMART General Committee 001 aware of additional tax forms being sent to the members in regards to medical coverage. Large employers like BNSF are subject to the "employer shared responsibility" provision of the Affordable Care Act and therefore must demonstrate that an offer of medical coverage was made to at least 70% of all full-time employees for 2015. As part of meeting this requirement, BNSF must send a Form 1095-C to all employees and file these forms with the IRS. Employees should receive these forms soon if they have not already received them.
SMART TD members should have already received a Form 1095-B from their multi-employer plan administrator so the Form 1095-C may seem like a duplicate copy. The law still requires that BNSF mail the 1095-C to their employees which indicate “no offer of coverage.” This is the correct method of reporting when the employee is covered by a multi-employer plan. It is the Form 1095-B which includes important information SMART members will need to complete their personal tax filings. Although Forms 1095-B does not need to be submitted with individual 1040 tax filing forms, employees should keep the 1095-B forms with their tax documentation in the event they are subject to an IRS audit.
The 1095-C is a legal requirement of the Affordable Care Act and is informational only. This form does not alter or impact employee coverage in any way and no action is required on the part of the employees.