The long-standing IRS FAQs related to reporting under sections 6055 and 6056 on requirements provided by the Patient Protection and Affordable Care Act (ACA) have been updated to reflect new information. Final instructions for both the 1094-B and 1095-B and the 1094-C and 1095-C were released in September 2015, as were the final forms for 1094-B, 1095-B, 1094-C, and 1095-C. On December 28, 2015, in Notice 2016-04, the IRS extended the information reporting due dates for insurers, self-insuring employers, other health coverage providers and applicable large employers. The updated FAQs take the information from Notice 2016-04 into account.
The 6056 FAQ, which discusses information reporting for applicable large employers (ALEs), and the 6055 FAQ, which discusses reporting on minimum essential coverage (MEC), clarify that the deadlines for fixing mistakes on forms has been extended due to the overall extension for information reporting. For statements furnished to individuals under sections 6055 and 6056, any failures that reporting entities correct by April 30 and October 1, 2016, respectively, will be subject to reduced penalties.
The 6056 FAQ also clarified that an employer may only issue one 1095-C per full-time employee.
UBA offers key resources to help employers understand the reporting provisions contained in the IRS FAQs and notices:
Final Forms and Instructions for Employer and Individual Shared Responsibility Reporting Forms: Employers with 50 or more full-time or full-time equivalent employees and insurers are now required to report on the health coverage they offer. This ACA Advisor has comprehensive information on what forms to use for employees, filing dates, responsible parties and forms to be sent to the IRS, including sample situations.
Template Letter to Employees about IRS Forms 1095-B and 1095-C: UBA has created a template letter that employers may use to draft written communication to employees regarding what to expect in relation to IRS Forms 1095-B and 1095-C, and what employees should do with a form or forms they receive. The template is meant to be adjustable so employers can add pertinent additional information.
IRS Provides Major Delay in 6055 and 6056 Reporting: This ACA Advisor explains the recent due date extensions, the extension process and the impact on employees.