The IRS has released draft forms for 2015 to help employers who are subject to the new information reporting requirements under the Affordable Care Act (ACA) prepare for compliance. Affected employers are required to report for the first time in early 2016 for calendar year 2015. In general:
- Forms 1094-C and 1095-C will be used by large employers (generally those with at least 50 full-time employees, including full-time equivalents) to report information to the IRS and to their employees about their compliance with “pay or play” and the health care coverage they have offered.
- Forms 1094-B and 1095-B will be used by insurers, self-insuring employers (regardless of size), and other parties that provide minimum essential health coverage to report information on this coverage to the IRS and to covered individuals.
Changes to 2015 Draft Form 1095-C
The new draft forms include certain changes from the 2014 forms (which were previously finalized for those employers that chose to voluntarily comply with the information reporting requirements for the 2014 calendar year). While the 2015 Draft Form 1095-C is generally unchanged from the 2014 Form 1095-C, a new field has been added for “Plan Start Month,” which is optional for 2015 (for 2016 and beyond, this field will be required). In addition, the 2015 Draft Form 1095-C includes a continuation sheet that filers use if they need to report coverage for more than six individuals.
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 guidance regarding the information reporting requirements for large employers subject to “pay or play” is available in separate IRS Questions and Answers.