More than four years after the Affordable Care Act was signed into law, employers are just now getting a complete picture of what’s required of them to comply with the employer “play-or-pay” mandate.
For years, the Internal Revenue Service (IRS) has been releasing info in dribs and drabs about the reporting requirements that will actually make enforcement of the employer mandate possible.
This past winter, the IRS attempted to lay out the two types of reporting that must be done:
- Tax Code 6055 reporting. This applies to insurers and sponsors of self-insured plans. What must be reported? Data about the entity providing insurance coverage — like the contact information for the company — and which individuals are enrolled in coverage, with identifying information and the months for which they were covered.
- Tax Code 6056 reporting. This applies to employers subject to the play-or-pay rules (employers with 50 or more full-time employees). What must be reported? Data about the organization — like the contact information for the company and the number of its full-time equivalent employees — and information about the coverage (if any) offered to each full-time employee, by month, including the lowest employee cost of self-only coverage offered.
Unfortunately for employers and insurers, these requirements weren’t issued with the forms that would be needed to complete the reporting. As a result, nobody knew exactly what would be asked of them.
Well, the IRS just released the draft reporting forms:
- Form 1094-B: Transmittal of Health Coverage Information Rules
- Form 1095-B: Health Coverage
- Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
- Form 1095-C: Employer-Provided Health Insurance Offer and Coverage
Form 1095-B will be sued to satisfy the reporting requirements under Tax Code 6055, and Form 1094-B will be used to transmit the 1095-B.
Form 1095-C will be used to satisfy the 6056 reporting requirements, and Form 1094-C will be used to transmit the 1095-C.
More to come
Still, in keeping with tradition, the IRS hasn’t yet painted the whole picture. While the draft forms have been released, instructions on how to fill out the firms haven’t.
The IRS says they will be provided in August. Stay tuned.