July 28, 2014
IRS Releases Draft Forms for Reporting Employee Health Coverage
By: Caroline E. Smith, Esq., Corporate Compliance Officer, AssuredPartners, Inc.
On July 24, 2014, the Internal Revenue Service (IRS) released draft versions of the forms that will be used by employers to report to the IRS information on health coverage offered to their employees as required by the Affordable Care Act (ACA). Though these forms are only drafts, employers may wish to review the drafts to begin to understand the information they will need to collect, some of which they may not currently have available to them, beginning in 2015. A statement accompanying the forms on the IRS website provides that the IRS anticipates that instructions to these forms will be available in August and the forms and instructions will be finalized later in the year.
As detailed in previous IRS regulations (and as addressed in our March 10, 2014 Compliance Observer), providers of minimum essential health coverage subject to Code §6055 (including issuers, non-applicable large employers (ALE), and others) must report certain health coverage and employee information to the IRS using Form 1095-B and submit the corresponding Form 1094-B “transmittal form.” All such providers must also provide statements to “responsible individuals.” In addition, ALEs who are subject to the Employer Mandate and Code §6056 must report detailed health coverage and employee information as required by the IRS on Form 1095-C and submit the Form 1095-B transmittal form. Employers subject to Code §6056 must also provide a statement to each full-time employee.
These IRS forms can be viewed by accessing the following links:
Once the draft instructions are released, by the IRS next month, and the final instructions and forms are released later this year, your AssuredPartners NL team will provide them to you. Of course, as always, your team is ready to assist with your ACA reporting strategy and compliance efforts.
Contact your AssuredPartners NL Benefit Team if you have questions or need assistance with these or other compliance matters