Who is Covered? When?
Applicable large employers (those with 50 or more full-time and FTE employees)
Employers with self-insured health plans
First due in 2016, related to 2015 coverage.
The Affordable Care Act ACA created new reporting requirements under Internal Revenue Code
Sections 6055 and 6056. Under these new reporting rules, certain employers will
be required to provide information to the IRS about the health plan coverage they
offer (or do not offer) to their employees (such as information on the design and
cost of their plans, as well as employees covered by the plan). Related
statements must also be provided to employees.
These new reporting requirements apply to:
- Employers with self-insured health plans (Code Section 6055)
Every health insurance issuer, sponsor of a self-insured health plan, government
agency that administers government-sponsored health insurance programs
and any other entity that provides minimum essential coverage must file
information returns with the IRS reporting information for each individual who
is provided with this coverage during the calendar year. Related statements
must also be provided to covered individuals.
- Applicable large employers (ALEs) (Code Section 6056)—ALEs subject
to the ACA’s employer shared responsibility rules must file information
returns with the IRS that reports the terms and conditions of the health care
coverage provided to the employer’s full-time employees for the calendar
year. Related statements must also be provided to full-time employees.
These reporting requirements were set to take effect in 2014. However, on July
2, 2013, the Treasury delayed these requirements for one year, until 2015.
The first returns will be due in 2016 for coverage offered or provided in 2015.
Returns must be filed with the IRS annually, no later than Feb. 28 (March 31, if
filed electronically) of the year following the calendar year to which the return
relates. Individual statements must be provided on or before Jan. 31 of the year
immediately following the calendar year to which the statements relate.
The employer shared responsibility rules were delayed for medium-sized ALEs
(those with 50-99 full-time and FTE employees in 2014) for one year, until 2016.
ALEs eligible for this delay must still report under Section 6056 for 2015.
ALEs reporting under Section 6056 will use Forms 1094-C and 1095-C. In general, entities reporting under Section 6055 will use Forms 1094-B and 1095-B. However, ALEs that sponsor self-insured plans must report under both Section 6055 and Section 6056. These employers will use a combined reporting method on Forms 1094-C and 1095-C to report the information required under both Section 6055 and Section 6056.
Penalties of $100 per return generally apply for any failures to file correct
information returns or provide correct individual statements by the deadlines.
However, short term relief from penalties is available in 2015 for reporting entities
that make good faith efforts to comply with the reporting requirements.
Action Items:
¨ Determine whether your organization is a sponsor of a self-insured health plan or an ALE.
¨ Begin tracking and recording the information that must be reported for the calendar year under Section 6055 and/or Section 6056, as applicable.
¨ When the reporting requirements become effective, provide required information regarding plan coverage and participation to the IRS and to individuals,
in accordance with information return requirements.
Documents Available from Valley Employee Benefits:
- HCR: ACA Employer Reporting of Health Coverage—Code Sections 6055 & 6056
- Q&As on ACA Employer Reporting of Health Coverage (Section 6056)
- Health Care Reform: Code Section 6056—What Information Must Be Reported?
- Affordable Care Act—Reporting Requirements for Applicable Large
Employers (Section 6056)
- Q&As on Reporting by Health Coverage Providers (Section 6055)
- Health Care Reform: Code Section 6055—What Information Must Be Reported?
- Affordable Care Act—Responsibilities for Health Coverage Providers
(Section 6055)
- IRS Releases Final Forms and Instructions for ACA Reporting
Tools Available from Valley Employee Benefits:
- Section 6056 Reporting Workbook
- Section 6055 Reporting Workbook
