IRS Releases Draft 2015 Forms 1094 and 1095

On Tuesday of this week, the IRS release 2015 versions of Form 1094 and 1095. These will be used to report information that is needed to satisfy and comply with both the Individual Mandate and the Employer Shared Responsibility provisions of the Affordable Care Act (in addition to assisting with the complex evaluation process for who qualifies for premium tax credits (subsidies for coverage)).

These drafts 2015 forms are virtually identical to their 2014 version.   However, there are always a few minor edits.

• Other than slight language-related differences, the draft 2015 “B” Forms as well as the draft 2015 Form 1094-C have not been changed.
• The draft 2015 1095-C Form does, however, indicate one anticipated change. The IRS added one new field on the draft 2015 1095-C Form to specify the month the Applicable Large Employer’s plan year begins. This new field is titled “Plan Start Month” and appears to be optional for the 2015 filing.
• Additionally, although not a substantive change, both Part III of the draft 2015 1095-C Form and Part IV of the draft 2015 1095-B Form includes a “continuation sheet.” This sheet is to be used for filers that are reporting enrollment information for more than six individuals.

Based on the information presented in the draft 2015 Forms, it does not appear that any significant changes will be made to the 2015 ACA reporting forms. However, until the IRS releases corresponding instructions for these forms and the final versions, we will not have all of the information to fully prepare for the 2016 filing deadlines. Until then, the IRS has made some additional information available on how employers and/or third parties should file through the IRS’s new electronic filing system. (See IRS draft Publication 5165 for more information.)

You may also like to review IRS Publication 5196 on the Employer Reporting Requirements (of the ACA). http://www.irs.gov/pub/irs-pdf/p5196.pdf

Links:

• Self-Funded chart (which forms do I need to prepare & file)
• Fully Insured chart (which forms does the Employer need to prepare and file vs the carrier)
• IRS Publication 5196 on the Employer Reporting Requirements (of the ACA).
• IRS Publication – IRS Affordable Care Act (ACA) Information Returns (AIR); AIR Submission Composition and Reference Guide (90 pages)
• Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
• Form 1094-B Transmittal of Health Coverage Information Returns
• Form 1095-C Employer-Provided Health Insurance Offer and Coverage
• Form 1095-B Health Coverage
• Form 1095-A Health Insurance Marketplace Statement
• IRS Draft Publication 5165 – Guide for Electronically Filing Affordable Care Act (ACA) Information Returns – For Software Developers and Transmitters

Other Guidance:

• 06/17/2015 Webinar: Affordable Care Act – Employer Reporting and Compliance Update
• 05/21/2015   IRS Provides Further Guidance on Reporting Employer Health Coverage Information on Forms 1094 and 1095
• 05/06/2015   IRS Tax Form 1095: How Will You Comply?
• 03/23/2015 Webinar: The Top 10 Affordable Care Act and IRS Compliance Issues for 2015
• 02/23/2015 IRS Reporting on Employer and Individual Mandates – Final Instructions
• 01/13/2015   IRS and HHS: Prepping for Your Tax Season PPACA Questions
• 08/06/2014   Informational Draft Transmittal and Reporting Forms Release by IRS
• 07/22/2014 BSwift ACA Management Suite
• 02/17/2014 Final IRS Regulations on Employer Shared Responsibility Provide Important Transition Relief and Make Other Important Changes to the Proposed Rules