On July 24, 2014, the Internal Revenue Service posted draft forms for the employer reporting required under the Affordable Care Act (ACA) in connection with the "pay or play" rules. These forms give some idea of the type and format of the information that will be required. No instructions were posted.
The specific forms which can be found at www.irs.gov/draftforms 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
- Form 1095-B Health Coverage
- Form 1094-B Transmittal of Health Coverage Information Returns
For a short description of the reporting requirements, click here for the September 26, 2013 Comp and Benefits Brief on "ACA Reporting – a Peek into the Future".
In addition, drafts of forms for individuals to file claiming premium tax credits or exemptions with respect to coverage obtained on the Exchanges were also issued:
- Form 8962 Premium Tax Credit (PTC)
- Form 8965 Health Coverage Exemptions
Unless the Exchanges provide detailed year-end information to individuals to attach to Form 8962, completion of the form as drafted will be a challenge for most individuals and may push these individuals with household incomes below 400% of the federal poverty level to obtain tax preparation services.
The IRS is seeking comments on these forms which can be submitted at http://www.irs.gov/uac/Comment-on-Tax-Forms-and-Publications.
Employers should begin now to review these forms with their payroll and IT departments to analyze the information required and how to collect and report it. Some questions may be answered when instructions are issued, but a preliminary review will better prepare employers.