The Internal Revenue Service (IRS) recently released draft forms to help employers prepare for the new information reporting provisions under the Affordable Care Act. Because of transition relief provided for 2014, reporting entities will not be subject to penalties if they first report beginning in 2016 for 2015.
ACA Information Reporting
The Affordable Care Act requires insurers, self-insuring employers, and other parties that provide minimum essential health coverage (MEC) to report information on this coverage to the IRS and to covered individuals. Large employers (generally those with 50 or more full-time employees, including full-time equivalents) are also required to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Final rules regarding MEC reporting and large employer reporting are currently available.
Draft Forms
As a general method, large employers will file Form 1094-C (a transmittal) and Form 1095-C (an employee statement). Entities reporting as health insurance issuers or sponsors of self-insured group health plans that are not reporting as large employers will generally report on Form 1094–B and Form 1095–B. The following forms are now available:
- Draft Form 1094-C (transmittal)
- Draft Form 1095-C
- Draft Form 1094-B (transmittal)
- Draft Form 1095-B
The applicable forms will be required to be electronically filed only if the reporting entity is required to file at least 250 of the specific form.
Draft instructions relating to the forms are expected to be posted to IRS.gov this month, and the IRS intends to finalize both the forms and instructions later this year. For more information on the reporting requirements, click here.
Be sure to check out our ACA by Year & Company Size section for updates on additional requirements related to Health Care Reform.