Smart Benefits: IRS Releases Draft Forms for ACA Reporting

Smart Benefits: IRS Releases Draft Forms for ACA Reporting

The Internal Revenue Service recently release draft forms large employers and those who sponsor self-funded plans will have to file to show their health coverage complies with both the employer and individual mandates under the Affordable Care Act (ACA) – or if they face a penalty.

Starting in 2016 for coverage provided in 2015, the forms, when final, will be used by employers for the new reporting provisions under tax code sections 6055 and 6056.

• Section 6055: health insurers and employers sponsoring self-funded group health plans must annually report whether the group health plan coverage constitutes minimum essential coverage under Health Care Reform using the following forms:

-1095-B Health Coverage, provided to enrollees and members
-1094-B Transmittal of Health Coverage Information Returns, filed with the IRS

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• Section 6056: employers must demonstrate they have satisfied the obligation to offer coverage to employees under the “pay or play” rules and furnish information to employees to determine their eligibility for a premium subsidy for coverage purchased through a health insurance exchange with the following forms:

-1095-C Employer-Provided Health Insurance Offer and Coverage, provided to each employee
-1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return, filed with the IRS

Mid-size employers with between 50 and 99 full-time employees don’t need to comply with the reporting requirements until the first day of the employer's 2016 plan year.

Expected to be final later in the year, the draft forms were released now to help companies prepare for the new reporting provisions, which will require monthly compilation of data on the employees. The IRS is currently inviting comments on the draft forms here.

Amy Gallagher has over 21 years of healthcare industry experience guiding employers and employees. As Vice President at Cornerstone Group, she advises large employers on all aspects of healthcare reform, benefit solutions, cost-containment strategies and results-driven wellness programs. Amy speaks regularly on a variety of healthcare-related topics, and is often quoted by national publications on the subject matter. Locally, Amy is a member of SHRM-RI, the Rhode Island Business Group on Health, and the Rhode Island Business Healthcare Advisory Council.