Last week, the IRS release draft forms that applicable large employers and health insurance issuers will use to report information regarding health coverage, as required under the Affordable Care Act starting in 2015.
At this time, draft instructions relating to the forms are not available; however, the IRS anticipates that draft instructions will be available in August. Both the forms and the instructions will be finalized later this year. The forms may be found by following these links:
- Form 1094-B: Transmittal of Health Coverage Information Returns
- Form 1095-B: Health Coverage
- Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return
- Form 1095-C: Employer Provided Health Insurance Offer and Coverage
Applicable large employers will satisfy their reporting requirements by filing Form 1094-C (a transmittal to the IRS) and Form 1095-C (a statement to employees). Applicable large employers that sponsor self-insured plans will complete both sections of Form 1095-C to satisfy their obligation, whereas an employer sponsor of a fully insured plan will complete only the top half of Form 1095-C.
The IRS will use Form 1095-C to assess an employer’s compliance with the pay-or-play mandate as well as whether an employee is eligible for premium tax credits to purchase coverage through the Health Insurance Marketplace. Employers must file Form 1094-C with the IRS by February 28 following the reporting year (March 31 if filing electronically) and must provide Form 1095-C to full-time employees by January 31 following the reporting year.
Health insurance issuers, including self-insured employer-sponsored plans, will satisfy their reporting obligations by filing Form 1094-B with the IRS and by providing Form 1095-B to covered employees, who will use the information to report compliance with the individual mandate on their federal income tax return. The IRS will use Form 1095-B to verify whether individuals have the minimum essential coverage necessary to comply with the ACA’s individual mandate.