The IRS released draft instructions for Form 1094-B and Form 1095-B. Draft instructions for the “C” forms were issued earlier this summer. See our article here.
The B Forms are used by insurance companies and small self-funded health plans to report coverage. The instructions have few changes from the 2015 versions, but do incorporate some clarifications.
- Taxpayer Identification Number. The Instructions reference the obligation of an employer to solicit a TIN at least 3 times.
- SHOP Plans. The Instructions confirm that coverage under a SHOP plan should be reported on the B forms.
- Excepted Benefits. The instructions clarify that excepted benefits (such as dental or vision only plans) are not minimal essential coverage and do not have to be reported.
- Coverage Under Multiple Plans. If an individual is covered under two plans from the same employer, the second “supplemental” plan providing minimum essential coverage is not reported.
Employers are waiting for the IRS to finalize the draft instructions so they can be relied upon for the 2016 reporting year.
