IRS Releases Employer Mandate Guidance

09/02/2014

The Internal Revenue Service (IRS) recently released draft health coverage forms which employers will have to complete and provide to employees starting in 2016. The IRS forms are necessary to determine whether an employer owes payments under the employer-shared responsibility provisions under PPACA. The forms also help determine whether an employee has health insurance as required under the PPACA individual mandate.

Employers with 50 or more full-time employees (including FT equivalent employees) will use Form 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. The employer is required to file Forms 1094-C and 1095-C with the IRS and to furnish a copy of Form 1095-C to the employee. For calendar year 2015, Forms 1094-C and 1095-C are required to be filed by February 29, 2016 (or March 31, 2016, if filing electronically).

The recent guidance from the IRS includes long-awaited instructions on how to complete these forms, including detailed descriptions of each line item. Since every employer is different in terms of number of employees, funding arrangement and location, it is important to go through these instructions well before the 2016 deadline to feel comfortable filling out each applicable section of the forms.

To access the draft IRS forms and instructions: http://www.irs.gov/pub/irs-dft/f1094c–dft.pdf, http://www.irs.gov/pub/irs-dft/f1095c–dft.pdf, http://www.irs.gov/pub/irs-dft/i109495c–dft.pdf .

For more information on the PPACA Reporting Provisions: http://www.wgains.com/Assets/Attachments/HRAT/ReportingProvisionsAug14.pdf

William Gallagher Associates will continue to monitor healthcare reform legislation and provide additional information on an ongoing basis. Please contact WGA’s Health Reform Advisory Team at healthreform@wgains.com with any questions, or check out WGA’s Health Reform Advisory Corner.