H&W: IRS Releases Draft Reporting Forms

If you want to see what the government is thinking in terms of reporting information that will be required to support the employer and employee mandates under the ACA, the IRS has recently released draft reporting forms.

As discussed in our previous blog post, Employer ACA Reporting Rules, employers providing minimum essential coverage must report information about that coverage to the government and employees under rules set forth in Section 6055. In addition, applicable large employers who are subject to the employer mandate, must report information as required in Section 6056.

Generally, the first filings will be due in early 2016 to report coverage provided in 2015, although voluntary reporting is encouraged for coverage provided in 2014.

Links to the drafts forms are provided below.  In accordance with the IRS’ normal process, these draft forms are being provided to help stakeholders prepare for the new reporting provisions and to invite comments from them. Draft instructions should be available sometime this month. The IRS has stated that both the forms and instructions will be finalized later this year.

Form 1094-B: Transmittal of Health Coverage Information Return

Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return

Form 1095-B: Health Coverage

Form 1095-C: Employer Provided Health Insurance Offer and Coverage