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The Internal Revenue Service (IRS) released draft forms on July 24 that employers will use to report on health coverage they offer to their employees, also known as information reporting requirements under the Affordable Care Act (ACA), which become effective for the 2015 calendar year. Employers with 50 or more full-time employees and full-time-equivalent employees as well as employers that self-insure are encouraged to learn more about the draft reporting forms by viewing an analysis prepared by Littler Mendelson, P.C.

Stakeholders are invited to submit comments on the draft forms. The IRS expects draft instructions to be posted in August on IRS.gov and anticipates that the reporting forms and instructions will be finalized later this year.

The Department of Treasury and the IRS issued final rules March 10 on information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans and information reporting of minimum essential coverage. The final rules relate to ACA’s employer and insurer information reporting requirements under Internal Revenue Code sections 6055 and 6056. For more information, ABC’s general counsel provided a detailed summary of the final rules.  

Section 6056 applies to large employers (with 50 or more full-time employees and full-time-equivalent employees). Applicable large employers are required to report information about the health care coverage they have offered to full-time employees to the IRS. They are also required to provide related statements to each full-time employee. The final rules discuss the content, method and timing of information required to be reported to the IRS and furnished to full-time employees. Further, it discusses alternative options for reporting. 

Under section 6055, health insurance issuers and self-insuring employers that provide minimum essential health coverage to individuals must report to the IRS information about the type and period of coverage and furnish related statements to covered individuals. The final rules discuss coverage subject to reporting; persons required to report; information required to report; time and manner of filing; combined reporting; and statements furnished to individuals.

The draft reporting forms released on July 24 include:

• Form 1094-B Transmittal of Health Coverage Information Rules
• Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
• Form 1095-B Health Coverage
• Form 1095-C Employer-Provided Health Insurance Offer and Coverage

ABC National will continue to educate members about the complicated information reporting requirements. Members also are encouraged to consult counsel about complying with the employer mandate and information reporting requirements. Additional information on the health care law may be found on ABC’s Employer Health Care Law Toolkit.