Informational Draft Transmittal and Reporting Forms Released by IRS
The Internal Revenue Service recently released initial drafts of forms for use in reporting health insurance coverage offered by applicable employers. Additionally, draft forms for minimum essential coverage by insurers and employers of self-insured plans were released, as well as a forum for public commentary. The draft forms are currently posted at IRS.gov/draftforms as information only. Final versions for actual filing will come at a later date.
These transmittal and reporting forms were noted in the Final Rules released on March 5, 2014. Initial 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.
Both insurers and employers of self-insured plans must report annually to the IRS and all individuals named in the report regarding whether the individual had minimum essential coverage. Thus the IRS will be able to confirm that 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.
Employers with 50 or more full-time employees must report on all 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.
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.
The IRS is open to comments on these forms, which should be submitted to the Comment on Tax Forms and Publications page on IRS.gov.
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