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The IRS has released draft ACA Reporting Forms and Instructions for 2018 (to be filed in 2019).

 

Background:

The Affordable Care Act (“ACA”) requires employers and providers of health insurance coverage to report certain information to the IRS and plan participants each year. The Section 6055 reporting requirements apply to health insurance providers, such as insurance companies and employers that provide self-insured group health plans. The Section 6056 reporting requirements apply to “applicable large employers” or “ALEs” and require reporting of health care coverage offered to the employer’s full-time employees (an ALE is an employer that employed 50 or more full-time equivalent employees on average in the prior calendar year).

Reporting under Sections 6055 and 6056 involves one or both of two sets of reporting forms: the “B” forms (Forms 1094-B and 1095-B) and the “C” forms (Forms 1094-C and 1095- C). Each set of forms includes a transmittal form (Forms 1094-B and 1094-C), which serves as a cover page. The B-Series forms are used to report whether individuals have minimum essential coverage and, therefore, are not liable for the individual shared responsibility payment. The C-Series forms are used to report information about offers of health coverage and enrollment in health coverage for employees, to determine whether an employer owes an employer shared responsibility payment, and to determine the eligibility of employees for the premium tax credit. ALEs that sponsor self-insured plans will perform their reporting using only the C-Series forms when reporting on full-time employees. The forms that must be filed and distributed depend on whether the employer is an ALE and the type of coverage provided.

The following chart summarizes the filing requirements:

Employer Type

 

IRC Section Forms Filed Form Provided to Employee Sent By
Small Fully Insured 6055 1094-B, 1095-B (filed by carrier) 1096-B Carrier
Small Self Insured 6055 1094-B, 1095-B 1095-B Employer
ALE Fully Insured 6055 1094-B & 1095-B (filed by carrier) 1095-B Carrier
ALE Fully Insured 6056 1094-C, 1095-C (Parts I & II filled out) 1095-C Employer
ALE Self Insured 6056 1094-C, 1095-C (Parts I, II, & III filled out) 1095-C Employer

 

Links to the Draft Forms:

C Forms

B Forms

 

Note: These forms and instructions have been released as drafts only.  Employers should wait to review the finalized forms.

 

The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog.

Joanna Castillo– Joanna is the Client Compliance Manager for Sequoia, where she works with our clients to optimize and streamline benefits compliance. In her free time, Joanna enjoys live music, college football, travel, and walking her dog in Golden Gate Park.