Last week the IRS released the FINAL 2015 versions of the forms 1095-C, 1094-C, and their corresponding instructions. All Applicable Large Employers (ALEs) are required to report information to the IRS regarding their employees and offers of health insurance for 2015.
Statements to Employees:
An ALE member must furnish the 1095-C statement to each full-time employee on or before January 31 of the year immediately following the calendar year to which the information relates. This means that the first Forms 1095-C (the statements for 2015) must be furnished to employees no later than February 1, 2016 (January 31, 2016, being a Sunday).
Returns to the IRS:
An ALE member must file Form 1094-C and Form 1095-C for each employee with the IRS on or before February 28 (March 31 if filed electronically) of the year immediately following the calendar year for which the offer of coverage information is reported. The first returns required to be filed are for the 2015 calendar year must be filed no later than February 29, 2016, or March 31, 2016, if filed electronically. New regulations under section 6081 address extensions of time to file information returns.
All ALEs should carefully read through the 17 page instruction booklet as there have been some reporting instruction changes since the release of the 2014 and 2015 DRAFT versions of these forms and instructions.
Of particular note in the new instructions is a clarification that Health Reimbursement Arrangements (HRAs) will not be subject to separate IRS Section 6055 reporting as long as they are integrated with the employer’s group health plan. (See instructions for additional details.)
For more information on ACA reporting for ALEs, please review the links below and be sure to watch your email for invitations to our upcoming Eastern Benefits Group webinars and workshops covering Employer ACA reporting.