The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code Sections 6055 and 6056, whereby certain employers and insurers must provide information to the IRS about the health plan coverage they offer or do not offer to their employees.

On February 8, 2015, the IRS released final versions of forms and instructions that employers can utilize for Sections 6055 and 6056 reporting on 2014. These forms are not required to be filed for 2014, rather reporting entities may voluntarily file them in 2015 for 2014 coverage. Employers should note that forms and instructions for 2015 reporting have not yet been released and may contain some changes from the 2014 versions.

Under Section 6055, every entity that provides minimum essential coverage (MEC) to an individual during a calendar year must file Forms 1094-B (a transmittal) and 1095-B (an information return). These entities include medical insurance carriers, self-insured medical plan sponsors, government agencies that administer government-sponsored health insurance programs, and any other entity that provides MEC. These forms help the IRS determine whether an individual has complied with the individual mandate or is subject to a penalty.

Under Section 6056, all applicable large employers (ALEs) with 50 or more full-time employees, must file Form 1094-C (a transmittal) and Form 1095-C (an information return) for each full-time employee. Form 1095-C will generally be used by ALEs to satisfy both the Section 6055 and 6056 reporting requirements. These forms help the IRS determine whether an ALE owes penalties under the employer shared responsibility rules, as well as whether an employee is eligible for any subsidies.

Self-insured plan sponsors that are also ALEs will report information about the coverage in Part III of Form 1095-C, instead of on Form 1095-B.

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