August 7, 2014
The IRS recently released draft forms to be used by employers and insurers for Health Care Reform’s information reporting on health coverage. The first reports will be due in 2016, based on 2015 calendar year information.
Background. Health Care Reform requires applicable large employers and plan sponsors of self-insured medical plans to report certain information to the IRS and employees. This information will be used to calculate employer mandate penalties and verify an individual’s eligibility for subsidies on the exchanges.
Draft Forms. The IRS recently released a draft Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and a draft Form 1094-C, the corresponding transmittal form, to allow employers to start preparing for these new reporting requirements and to invite comments. For fully-insured coverage, the insurance carrier is responsible for plan reporting, and the employer only completes the employer portion of Form 1095-C.
Required Information. For a list of the information required to be included in the form, please see our prior HRBenefits Authority from March 31, 2014.
In addition to these requirements, the draft Form 1094-C requests names and employer identification numbers of other large employers within the controlled group that had employees at any time during the calendar year. This means that employers will need to have a record of all other employers in its controlled group when completing the filing.
Instructions Not Yet Issued. The draft forms were not accompanied by instructions. However, the IRS anticipates that draft instructions to the forms will be posted sometime in August.
Because these forms are in draft form only, it is possible that they will be amended prior to the release of final forms, which is scheduled for later this year.
Next Steps. Until final versions are released, these draft forms may be used as a guide for employers to start (i) determining what information will need to be tracked, and (ii) implementing a process for doing so. Although the first reports will not be due until 2016, information will need to be gathered beginning in 2015.
Contact Information. For more information from Mazursky Constantine, please contact Don Mazursky (404.888.8840), Amy Heppner (404.888.8825), or Kelly Meyers (404.888.8838). For information from VCG Consultants, please contact Leslie Schneider (770.863.3617).