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IRS Provides Guidance for Affordable Care Act Information Reporting


8/26/15

Synopsis

The IRS has provided guidance on the Affordable Care Act (ACA) information reporting requirements. A brief summary of this information, including which forms to file, what information to report, and when to file, is provided below.

Issue

The ACA’s information reporting requirements go into effect for coverage offered (or not offered) in calendar year 2015. Employers are required to furnish statements to the IRS and to employees in 2016.

Information Reporting under Section 6055

IRC section 6055(a) requires all health insurance issuers, as well as other entities providing minimum essential coverage, to file annual information returns with the IRS. They must also furnish a statement to individuals. Health insurance issuers use Forms 1094-B, Transmittal of Health Coverage Information Returns, as well as Form 1095-B, Health Coverage, to comply with this annual reporting requirement. The information returns are due no later than February 28, 2016 (March 31, 2016 for electronic filers). The IRS has issued guidance on information reporting by health coverage providers in the form of a Q&A page, which can be found here. It has also published detailed information designed to help healthcare providers understand their reporting responsibilities in Publication 5215, Affordable Care Act: Reporting Responsibilities for Health Coverage Providers.

Healthcare providers must report the following information:

  • The name, address, and employer identification number (EIN) of the provider
  • The name and taxpayer identification number (TIN), or date of birth if a TIN is not available, of each individual covered under the policy or program and the months for which the individual was enrolled in coverage and entitled to receive benefits; and
  • For coverage provided by a health insurance issuer through a group health plan, the name, address, and EIN of the employer sponsoring the plan. Additional information on whether the coverage is a qualified health plan enrolled in through the Small Business Health Options Program (SHOP) and (except for 2014 coverage reported in 2015) the SHOP’s identifier is also required.
     

Information Reporting under Section 6056

IRC section 6056 requires applicable large employers (those employing an average of at least 50 full-time employees during the preceding year) to furnish annual information reports. These reports must be furnished to full-time employees, and to the IRS, disclosing the nature of the health insurance offered. Employers meet the information reporting requirements by filing Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer Provided Health Insurance Offer and Coverage. The information returns are due no later than February 28, 2016 (March 31, 2016 for electronic filers). The IRS has issued guidance on information reporting by health coverage providers in the form of a Q&A page, which can be found here. It has issued guidance for completing Forms 1094-C and 1095-C in another Q&A page, which can be found here.

Information Reporting Deadline Extension Requests

Employers may request an extension of the ACA’s information reporting deadlines by using Form 8809, Application for Extension of Time to File Information Returns. The IRS will issue additional guidance soon by revising IRS Publication 1220.

What Does CohnReznick Think?
In light of the new information reporting requirements, employers should become familiar with the information to be included on these forms and develop procedures so they are filed on a timely basis to avoid penalties.

Contact

For more information, please contact Kenneth Kanter, Partner and Tax Practice Managing Director, at kenneth.kanter@cohnreznick.com or 973-364-6668.


Any advice contained in this communication, including attachments and enclosures, is not intended as a thorough, in-depth analysis of specific issues. Nor is it sufficient to avoid tax-related penalties. This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.
 

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