H&W: IRS Releases Draft Reporting Instructions
In an update to our earlier blog on draft forms for Sections 6055 and 6056 reporting, the IRS has now released draft instructions to accompany those forms. The IRS has indicated that they will finalize the forms and instruction some time in 2014.
As a quick refresher, section 6055 requires reporting from every person that provides minimum essential coverage. The 6055 reporting obligation for employers with insured coverage falls on the insurer. However, plan sponsors (i.e., the employer, in most cases) are responsible for reporting self-insured employer coverage.
Section 6056 reports must be filed by all employers who are subject to the ACA’s shared responsibility provisions (those with 50 or more full-time equivalent employees in the prior calendar year).
Affected employers may wish to review the applicable draft forms as they provide an indication of the type and level of detail required to complete them. For example:
- The forms would require an employee-by-employee listing along with the months during which they were covered.
- Employers must combine the information for employees that work for different divisions of the same company into a single report.
- In contrast, an employee who worked for different member companies in a controlled group of companies must be reported separately by each company.
- An employer may need to report each employee’s share of the lowest cost monthly premium for self-only minimum value coverage.
- An employer may need to report the number of full-time employees it had in each month, excluding employees in a limited-non-assessment period.
- An employer may need to report Social Security Numbers or date of birth for all individuals covered. Employers that do not have SSNs for covered spouses and dependents will need to make “reasonable efforts,” outlined in the regulations, to obtain them.
Although the first filings are not due until early 2016, employers should begin assessing whether they currently collect all the information needed to prepare the forms and whether their IT systems can handle electronic filing (required for filers of 250 or more returns.)
Links to the draft forms, instructions and Q&As are provided below:
Instructions for Forms 1094-C and 1095-C
Instructions for Forms 1094-B and 1095-B
Questions and Answers on Information Reporting by Health Coverage Providers (Section 6055)
