IRS Issues New Forms And Instructions Regarding The Employer Mandate Information Reporting Requirements Under The ACA

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In order to administer and enforce the rules of the Employer Shared Responsibility Mandate, the Affordable Care Act (ACA) added Sections 6055 and 6056 to the Internal Revenue Code, which require insurance providers and applicable large employers (ALEs) to file information returns with the IRS about the health coverage the ALEs provide to participants. Additionally, ALEs must also provide statements to their full-time employees about the ALE’s health coverage.  Recently, the IRS issued drafts of the forms and form instructions pertaining to the Section 6055 and 6056 reporting obligations.  Specifically, ALEs must file Forms 1095-C and 1094-C with the IRS, and provide a copy of Form 1095-C to employees.  The first set of forms will not be due until early 2016 for the 2015 calendar year; voluntary filings may be made for the 2014 calendar year.  The 1095-C and 1094-C forms must be filed with the IRS by February 28 (for paper filings), or March 31 (for electronic filings) of the year following the calendar year to which the return relates.  Because 2016 is a leap year, the due dates for the 2015 calendar year are February 29, 2016, and March 31, 2016, respectively.  Form 1095-C must be furnished to employees by January 31 of the year following the year to which the return relates (i.e., January 31, 2016 for 2015).  Even though the forms are not due until 2016, ALEs should familiarize themselves with the content of the forms in order to understand the data required and to verify the accuracy of the data collected to avoid any reporting penalties. Fortunately, in related answers to FAQs, the IRS has stated that it will not impose penalties on ALEs that can show that they have made good faith efforts to comply with the information reporting requirements for the 2015 reporting period.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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