August 11, 2015
Forms Due in 2016, Used to Report Health Coverage & ACA Compliance
The IRS has released 2015 Draft Instructions for Forms 1094-B and 1095-B and 2015 Draft Instructions for Forms 1094-C and 1095-C to help employers prepare for the new information reporting provisions under the Affordable Care Act. Employers are required to report for the first time in early 2016 for calendar year 2015.
Who is Required to Report
As a reminder, Forms 1094-B and 1095-B will be used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals. Large employers (generally those with 50 or more full-time employees, including full-time equivalents) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions ("pay or play") and the health care coverage they have offered.
Note: Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including full-time equivalents) will satisfy their reporting obligations using Forms 1094-C and 1095-C. Form 1095-C includes separate sections for reporting under each provision.
2015 Draft Forms
Final versions of the 2014 forms were previously released for those employers that chose to voluntarily comply for the 2014 calendar year. The following draft forms are now available for 2015:
Forms 1095-B and 1095-C must be electronically filed if the employer is required to file at least 250 of the specific form.
For More Information
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Additional details on the information reporting requirements for providers of minimum essential coverage, including self-insured employers, are available in IRS Questions and Answers. More information about the information reporting requirements for large employers subject to "pay or play" is available in separate IRS Questions and Answers.