April 22, 2014

You can relax…for now.  These reporting requirements are not required until early 2016 (for the 2015 calendar year); however, you’ll want to familiarize yourself with what is lurking around the corner.  Interestingly, we (The Insurance Group) recently had a conversation with a major national insurance carrier regarding these requirements and to our surprise, they were lost and didn’t know how this will be taken care of on their end (for fully-insured cases).  These potholes are indeed complicated, but I have faith that they will figure this out before long.

The recent updates are for Code Sections 6055 and 6056 final regulations which  outline the requirements under health care reform for informational returns and individual statements. 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.

Section 6055

Section 6055 applies to anyone who provides minimum essential coverage to a person during a calendar year.  It also requires furnishing of statements to full-time employees.

Generally, information required for Section 6055 reporting includes:

• Information about the entity providing coverage, including contact information.
• Which individuals are enrolled in coverage, with identifying information and the months for which they were covered.

Who Must File the Return?

In the case of:

• An employer that provides coverage through an insurance policy, the insurer must file.
• An employer that provides coverage through a self-insured plan, the plan sponsor must file.
• A government-sponsored plan, the executive department of the governmental unit must file.

Section 6056

Section 6056 reporting applies to “applicable large employers” or ALEs.  These are employers who are subject to the ACA’s shared responsibility requirements.

Generally, information required for Section 6056 reporting includes:

• Information about the employer offering coverage (including contact information and the number of full-time employees).
• For each full-time employee, information about the coverage (if any) offered to the employee, by month, including the lowest employee cost of self-only coverage offered.

Who Must File the Return?

The employer is responsible for filing the return, regardless of whether the employer self-insures or purchases an insurance policy.  In the case of employers in a controlled group, each employer within the group that has full-time employees must file a return.

Several highlights of the final regulations and fact sheet include:

Single, Combined Form for Information Reporting

The final rules provide for a single, consolidated form that employers will use to report to the IRS and employees under both sections 6055 and 6056.

Simplified Reporting Alternatives

Employers that provide a “qualifying offer” to their employees and employers that offer affordable, minimum value coverage can take advantage of simplified reporting alternatives.

Streamlined information

The final rules omit data elements in the statute that are not necessary to understanding coverage offered and provided.

The Insurance Group will keep our clients posted on new developments, but we also offer automated compliance tools that alert you when you need to take action on regulatory issues.  Please reach out to Jason Swindle (swin@tigadvisors.com) for more details.