The Internal Revenue Service (IRS) released initial drafts of forms to be used in reporting health insurance coverage offered by applicable employers, and minimum essential coverage by insurers and employers of self-insured plans. The IRS has posted the draft forms at IRS.gov/draftforms as information only, and will post final versions for actual filing at a later date. Instructions for these forms are expected to be issued later this summer.
These transmittal and reporting forms were noted in the Final Rules released on March 5, 2014, which we alerted on March 7. The first reporting is required in early 2016 for the 2015 calendar year, however employers are encouraged to voluntarily report coverage information in 2015 for the 2014 calendar year.
Reporting on the Individual Mandate
Insurers and employers of self-insured plans (regardless of size) must report annually to both the IRS and any individual named in the report whether the individual had minimum essential coverage. It is the means by which the IRS can confirm such individuals have complied with the “individual mandate.” When employers self-insure their plans, they may report on compliance with both the individual and employer mandates on one form.
Reporting on the Employer Mandate
Employers with 50 or more full-time employees (including full-time equivalents) need to report on all of the employees offered coverage during the prior calendar year. This information must be provided to the IRS and all employees identified as being offered employer-sponsored health coverage.
Draft Forms
Insurers and employers have two forms they must provide the IRS. Each must provide a form that serves as a cover letter as well as forms providing data on the individual or employer mandate. The forms are to be completed and filed as follows:
Employers will file Form 1094-C (a transmittal/cover sheet) to the IRS only, and Form 1095-C to both the IRS and named individuals. If its plan is insured, the employer will only complete Parts I and II of Form 1095-C.
Insurers will send Form 1094-B (a transmittal/cover sheet) to the IRS only, and Form 1095-B to both the IRS and named individuals for insured coverage only.
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