The Internal Revenue Service recently released draft versions of the forms that will be used to meet the shared responsibility reporting requirements under the Affordable Care Act (ACA). These draft forms have been released for comment and may not be used for filing until they are finalized. Instructions for the forms have not yet been issued, even in draft form. Those instructions may be even more informative than the forms themselves in providing additional guidance on the reporting requirements.
The issuance of these forms has been much anticipated since the Treasury Department issued tax regulations on the reporting requirements for both the individual mandate and the employer mandate in March. The reporting requirements are designed to notify the government about whether individuals and employers are meeting their obligations concerning health coverage under the ACA and to provide relevant information to individuals about their coverage and qualification for a subsidy through a health insurance exchange.
The forms aim to fulfill the reporting requirements as follows:
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6055 COMPLIANCE
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6056 COMPLIANCE
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Health insurance issuers, sponsors of self-funded health plans, and other entities that provide minimum essential coverage (MEC) must file:
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Applicable large employers that employed an average of at least 50 full-time employees (including full-time equivalents) on business days during the preceding year must file:
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Form 1094-C transmittal page
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Special Rule: As part of an effort to streamline the reporting process, applicable large employers that sponsor self-funded health plans are to report the information required of them for both the individual and employer mandates on a single combined form using Form 1095-C. Substitute forms will be permitted if they include all of the content required by the prescribed forms and meet other IRS requirements.
Employers will need to update their recordkeeping systems to gather efficiently the month-by-month information required under the shared responsibility reporting requirements for the 2015 calendar.
As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the ACA.
