The IRS has released draft
forms for reporting mandated by PPACA under Internal Revenue Code
Sections 6055 and 6056.
Code Section 6055 reporting
verifies the months during which covered individuals have minimum
essential coverage for purposes of enforcing PPACA's individual
mandate. Code Section 6056 requires information about the group
health plan coverage offered by large employers to full-time
employees for purposes of determining compliance with PPACA's
employer mandate. The IRS issued final regulations on these reporting
requirements earlier this year. (See the Alert of 3/20/14.)
PPACA requires large employers (with 50 or more full-time equivalent
employees) to report information to the IRS and to employees about
the group health coverage it provides and the employees who are
eligible for such coverage. IRS needs this information to: (i)
administer PPACA's individual and employer mandates; and (ii) to
determine which employees may be eligible for a premium tax credit if
they purchase health insurance through a Health Insurance
Section 6055 Forms.
Large employers that sponsor self-funded health plans (and other
entities that provide minimum essential coverage, such as insurance
carriers and governmental agencies) are subject to the Code Section
6055 reporting requirement and must also furnish an individual
statement to individuals who enroll in minimum essential coverage.
Employers will use Form
1095-B, "Health Coverage," to comply with the Section 6055
individual statement requirement, and Form 1094-B, "Transmittal
of Health Coverage Information Returns," to transmit this
information to the IRS.
Section 6056 Forms.
Employers subject to PPACA's employer mandate are subject to the
Section 6056 reporting requirements and must also furnish an
individual statement to each full-time employee.
Employers will use Form
1095-C, "Employer-Provided Health Insurance Offer and
Coverage," to meet the Section 6056 individual statement
requirement, and Form 1094-C, "Transmittal of Employer-Provided
Health Insurance Offer and Coverage Information Returns," to transmit
this information to the IRS.
Employers that sponsor self-funded plans will report the information
required under Sections 6055 and 6056 on a single, combined form
using Form 1095-C.
Employers must satisfy PPACA's minimum essential coverage information
reporting requirement for calendar years beginning after December 31,
2014. Paper versions of the 2015 information reports must be filed
with the IRS no later than February 28, 2016, and electronic versions
must be filed no later than March 31, 2016.
Electronic filing is
required for all employers filing at least 250 returns, while those
filing less than 250 returns may opt to file paper forms. Information
regarding each full-time employee is counted as a separate return.
Employers must furnish the 2015 reports for full-time employees no
later than January 31, 2016.
Action Steps for Large
Employers. Although the Forms are
currently only draft versions, they provide valuable insight on the
information that employers will need to collect and report to the IRS
and to employees. Employers are advised to start planning on how they
will meet these reporting requirements.