Employer Reporting of Health Coverage—Code Sections 6055 & 6056
The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) to their employees. The additional reporting is intended to promote transparency with respect to health plan coverage and costs. It will also provide the government with information to administer other ACA mandates, such as the large employer shared responsibility penalty and the individual mandate.
On March 5, 2014, the Internal Revenue Service (IRS) released two final rules on these reporting requirements, which apply for calendar years beginning after Dec. 31, 2014. This date reflects a one-year delay provided in IRS Notice 2013-45. However, the IRS is encouraging voluntary compliance for 2014. The IRS also released Q&As on Section 6055 and Q&As on Section 6056, which were updated in May 2015. In addition, the IRS released a separate set of Q&As on Employer Reporting using Form 1094-C and Form 1095-C, on May 28, 2015.
On Feb. 8, 2015, the IRS released final versions of forms and instructions that employers will use to report under Sections 6055 and 6056 for 2014. These forms are not required to be filed for 2014, but reporting entities may voluntarily file them in 2015 for 2014 coverage.
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