New Internal Revenue Code Sections 6055 and 6056 require that large employers (those with 50 or more full-time equivalent employees) and employers that sponsor self-funded group health plans file new IRS Forms 1094 and 1095 beginning in January 2016. A Form 1095 gets sent to all full-time employees regardless of whether they were offered group health plan coverage or if they enrolled. It also gets sent to any employee, former employee or COBRA beneficiary enrolled in an employer’s self-funded group health plan. The Form 1094 gets sent to the IRS along with a copy of every Form 1095 sent to employees and participants.    

To further complicate matters, the IRS has put out three versions of each of these forms, the A, B and C versions. Employers don’t need to concern themselves with version A as those are only required to be filed by insurers who offer plans through the public exchanges. However, an employer does need to know whether to file version B or C. Hopefully, the chart below will help you understand what version of the Form you need to file.

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