IRS Reporting on Employer and Individual Mandates – Final Instructions

IRS Reporting on Employer and Individual Mandates – Final Instructions


On February 9, 2015, the Internal Revenue Service (IRS) released final forms and instructions for reporting on individual and employer mandates. The instructions and forms will be used by applicable large employers, insurers and employers with self-insured plans.

The Final Rules on Minimum Essential Coverage (MEC) and Large Employer reporting were released on March 5, 2014. The first reporting is required in early 2016 for the 2015 calendar year. Employers had the option to voluntarily report 2014 information by January 31, 2015 for the 2014 calendar year, but it was not required.

What the Instructions Cover

The instructions provide an overview of why the forms/reporting are required. They also cover basic information including:

  • who must complete the forms
  • how the transmittal forms need to accompany their respective 1095-B or 1095-C Forms
  • where to mail paper forms; details for filing electronic forms are expected when the IRS posts Publication 5165
  • specific line by line instructions
  • general directions for contact person, signature on form and phone number
  • definitions of various terms used in reporting data
  • minimum guidance on multi-employer arrangements
  • transitional relief for off-calendar year plans

Required Forms

There are two forms required for each set of information being reported: 1) a transmittal form that serves as a cover letter; and 2) forms providing data on either the individual or employer mandate, or both for self-insured employer sponsors. The instructions and respective forms to be completed and filed are as follows:

Instructions for employers to 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.

Instructions for insurers to 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.

These instructions and forms can be found on the IRS website.  You may also find the IRS’ publication Affordable Care Act: Reporting Requirements for Applicable Large Employers, which discusses getting ready for monthly tracking and preparing to fill out new IRS forms in 2016 (for the 2015 plan year).

When do the IRS Reports/Forms need to be filed/sent?
Submitting 1095-C’s and 1094-C’s is optional for calendar year 2014 and mandatory for 2015.

Key dates for 2015 include:

  • January 31, 2016: All employees receive their 1095-C.
  • February 28, 2016: The 1094-C form is mailed to the IRS.
  • March 31, 2016: If more than 250 1095-C’s are issued, the 1094-C must be submitted electronically to the IRS.

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