Health Care Reform: Recent News & Events

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On August 28, 2014, the Internal Revenue Service (IRS) released draft instructions for previously released draft forms to help employers prepare for the new information reporting provisions under the Affordable Care Act (ACA). The draft instructions provide information on who must file, when to file, along with specific instructions for filling out the forms.

Background

The ACA requires insurers, self-insuring employers, and other parties that provide minimum essential health coverage (MEC) to report information on this coverage to the IRS and to covered individuals (referred to as "section 6055 reporting").

 

Large employers (generally those with 50 or more full-time employees, including full-time equivalents) are also required to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions ("pay or play") and the health care coverage they have offered (referred to as "section 6056 reporting").

Draft Instructions for Section 6056 Reporting (Forms 1094-C and 1095-C)

The general instructions provide that employers with 50 or more full-time employees must:

• File one or more Forms 1094-C (including an Authoritative Transmittal); and
• File a Form 1095-C (or a substitute form) for each employee who was a full-time employee of the employer for any month of the calendar year.

Eligibility for 2015 transition relief will also be reported on Form 1094-C, and the specific form of relief for which the employer is eligible must be reported using either code A (transition relief for employers with 50-99 full-time employees, including FTEs) or code B (transition relief for employers with 100 or more full-time employees, including FTEs).

Draft Instructions for Section 6055 Reporting (Forms 1094-B and 1095-B)

According to the general instructions, entities that provide MEC to individuals during a calendar year must file an information return and a transmittal. Most filers will use Forms 1094-B (transmittal) and 1095-B (return). However, employers subject to "pay or play" that sponsor self-insured group health plans will report information about the coverage in Part III of Form 1095-C (discussed above), instead of on Form 1095-B.

Filing Deadlines

Because of previously provided transition relief, none of the information reporting forms are required to be filed for 2014.The first required filings will be in 2016 for calendar year 2015. However, reporting entities may voluntarily file in 2015 for calendar year 2014.

For calendar year 2015, the information reporting deadlines are as follows:

Section 6056 Reporting

• Forms 1094-C and 1095-C must be filed by February 29, 2016 (or March 31, 2016, if filing electronically).
• The first Forms 1095-C are due to individuals by February 1, 2016.

Section 6055 Reporting

• Forms 1094-B and 1095-B must be filed with the IRS on or before February 28, 2016 (or March 31, 2016 if filing electronically). (If the regular date falls on a Saturday, Sunday, or legal holiday, entities may file by the next business day.)
• Forms 1095-B must be furnished to individuals on or before January 31, 2016. (If the regular date falls on a Saturday, Sunday, or legal holiday, entities may file by the next business day.)

Specific instructions for filling out the forms, along with information on where to file, are also included in the draft instructions. The IRS intends to finalize both the forms and instructions later this year.

For more information on the reporting requirements, click here.