The IRS has issued final versions of the forms and accompanying instructions to be used by employers for health coverage information reporting required under the ACA’s employer mandate rules. These information reporting rules are set forth under Code Sections 6055 and 6056.
As we wrote in a previous alert, Code Section 6055 requires health insurers and employers (regardless of size) that sponsor self-insured health plans to report information regarding individuals covered under their health plans. This information must be reported using Form 1095-B, indicating the months for which each family member had health coverage during the previous calendar year. Each primary insured person or employee must also be provided a copy of Form 1095-B with his/her pertinent information. All Forms 1095-B must be transmitted to the IRS using Form 1094-B as a transmittal form. The final instructions for Forms 1094-B and 1095-B can be found here.
Code Section 6056 requires employers with 50 or more full-time employees to report certain information regarding offers of “minimum essential coverage” to their employees and their dependents, including the months for which coverage was offered, and the lowest monthly cost for self-only coverage. Employers must report this information using Form 1095-Cand provide each employee with a copy of Form 1095-C with his/her pertinent information. All Forms 1095-C must also be transmitted to the IRS using Form 1094-C (which also requests additional information regarding other members of the reporting employer’s controlled group) as a transmittal form. The final instructions for Forms 1094-C and 1095-C can be found here.
Employers with 50 or more full-time employees who provide self-insured coverage may use the “C” series forms to satisfy all of their reporting obligations, and need not file separately using the “B” series forms. In addition to the final versions of the reporting forms, the IRS also published a short guide summarizing the reporting requirements applicable to large employers.
The first required reporting under Code Sections 6055 and 6056 is for the 2015 calendar year, and must be submitted in early 2016.