The ACA, IRS and the Paper Blizzard to Come
The ACA added two health coverage reporting requirements to the Internal Revenue Code. Both take effect for 2015, with the first reports due in early 2016:
IRC § 6056 requires large employers (50 or more full-time employees including full-time equivalents) to file annual reports detailing the health coverage they offer to full-time employees. Information will include employee names and SSNs, along with indicators (codes) about the type of health coverage offered.
Large employers will give a Form 1095-C to each employee, and also file these forms with the IRS using transmittal Form 1094-C. Caution: Large employers are those with 50 or more full-time employees (including full-time-equivalents). Mid-size (50-99) employers and/or some employers with non-calendar year plans may qualify for short-term transition relief that delays the requirement under the ACA’s “play or pay” rules until 2016.
IRC § 6055 requires insurers and self-funded plan sponsors to file annual reports detailing the health coverage provided to each individual. This includes any employer, large or small, that sponsors a self-funded health plan. For this purpose, employers will provide Form 1095-B to plan enrollees and members, and also file these forms with the IRS using transmittal Form 1094-B. Large employers that also sponsor a self-funded health plan can use Form 1095-C to satisfy both the § 6056 and 6055 reporting requirements.
On July 24, the IRS posted preliminary drafts of Forms 1094-B, 1094-C, 1095-B, and 1095-C. Draft instructions will not be posted until next month. The IRS expects to finalize the forms and instructions later this year. For copies of the draft forms, see:
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 Information Returns.
Form 1094-B, Transmittal of Health Coverage Information Returns.
As you can see the reporting of Health Care coverage to the IRS will be nothing less than an incredible strain on your HR departments work load. VanBeurden can help you with the reporting forms and make sure that you get and stay compliant. Why not take a minute and give me a call and we can have a meaningful discussion on ways to lessen this burden.
Guy Teafatiller PWCA, CWCA