IRS Releases Final 2015 Forms and Instructions for Employers to Report Health Coverage and ACA Compliance

October 1, 2015

in Compliance

First Information Returns Due in 2016

The Internal Revenue Service (IRS) has released finalized forms and instructions for 2015 to help employers prepare for compliance with the new information reporting provisions under the Affordable Care Act (ACA). 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 or FTEs) 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 FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C. Form 1095-C includes separate sections for reporting under each provision.

2015 Forms and Instructions
Final versions of the 2014 forms were previously released for those employers that chose to voluntarily comply for the 2014 calendar year. The following forms and instructions are now available for 2015:

•  Form 1094-C (transmittal)
•  Form 1095-C
—   2015 Instructions
•  Form 1094-B (transmittal)
•  Form 1095-B
—  2015 Instructions

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
Additional details on the information reporting requirements for providers of minimum essential coverage, including self-insuring 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.

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