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The Wagner Law Group Description 

The Wagner Law Group, A Professional Corporation, is a nationally recognized ERISA & employee benefits, estate planning, employment, labor & human resources practice. 


Established in 1996, The Wagner Law Group has 22 attorneys engaged exclusively in employee benefits, estate planning and employment law. Six of our attorneys are AV rated by Martindale-Hubbell as having very high to preeminent legal abilities and ethical standards. The firm is among the largest ERISA boutiques in the country. Our practice is national in scope, with clients in more than 40 states and several foreign countries.






Contact Info

The Wagner Law Group


  Integrity | Excellence


Massachusetts Office 

Tel: (617) 357-5200 

Fax: (617) 357-5250 

99 Summer Street 

13th Floor

Boston, MA 02110

Florida Office 

Tel: (561) 293-3590
Fax: (561) 293-3591
7108 Fairway Drive
Suite 125
Palm Beach Gardens, FL 33418


San Francisco Office

Tel: (415) 625-0002

Fax: (415) 358-8300

315 Montgomery Street

Suite 904

San Francisco, CA 94104







August 21, 2014


 Health and Welfare Law Alert




IRS Releases Draft Forms for PPACA's Employer Reporting Requirements




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.)


Background. 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 Marketplace.


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.  

NOTE: 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.


Filing Requirements. 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.   




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This Newsletter is provided for information purposes by The Wagner Law Group to clients and others who may be interested in the subject matter, and may not be relied upon as specific legal advice.  This material is not to be construed as legal advice or legal opinions on specific facts. Under the Rules of the Supreme Judicial Court of Massachusetts, this material may be considered advertising.