IRS Releases Final Forms and Instructions for ACA Reporting Requirements

Feb 17, 2015
2 min read

The Internal Revenue Service (IRS) has released final forms and instructions to be used for Internal Revenue Code § 6055 and § 6056 reporting. This material is for 2014 reporting, which is voluntary for employers. Reports for 2015 (due in early 2016) will be required, however, so employers and their advisors should review the material and begin preparing now.

Forms and instructional materials include:

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.
Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.
Instructions for Forms 1094-C and 1095-C.
A short brochure designed by the IRS to help employers understand the reporting requirements and the type of information needed to complete the forms.

Reporting Requirements

Code § 6056 requires applicable large employers (ALEs) to file annual reports detailing the health coverage they offer to full-time employees. For 2015, an ALE is an employer that had an average of 50 or more full-time employees, including full-time-equivalent employees, in 2014. To comply with this requirement, ALEs will provide a Form 1095-C to the employee and file a copy, along with transmittal Form 1094-C, with the IRS.

Code § 6055 requires health insurers, and employers that provide minimum essential coverage (MEC) through a self-funded health plan, to provide an annual statement to covered persons. Forms 1095-B and 1094-B are designed for this purpose; however, self-funded employers that are ALEs do not need these forms, and instead may use Forms 1095-C and 1094-C (above) to satisfy the requirements under both § 6055 and § 6056.

Simplified reporting options: The IRS provides a simplified reporting method for ALEs that make qualifying offers of coverage to full-time employees (and children) for all 12 calendar months of the reporting year. This simplified alternative allows the employer to report without identifying or specifying the number of employees. Simplified reporting also is available for employers that offered affordable minimum value coverage for all 12 months of the calendar year to at least 98 percent of its full-time employees (and children).

Action Steps for Employers:

Determine whether the 2015 reporting requirement applies to your organization. Generally, any employer with 50 or more full-time-equivalent employees (based on average count in 2014) is subject to the § 6056 reporting requirement for 2015.
Familiarize yourself with the reporting forms and instructions to understand the type of data you need to collect to complete the reports for 2015.
Make sure that your human resources and payroll systems are capturing that data and can produce the reports to comply with the new reporting requirements.
Consult with your payroll vendor and tax advisors to determine whether you will qualify for simplified reporting instead of the detailed reporting requirements. Source: thinkHR.com