The IRS released final Forms 1094-B/C and 1095-B/C along with final instructions. Employers will use these forms to meet their 2015 health care reform reporting obligations. The B series of forms are used by health care providers, including insurers and self-funded small employers. The C series of forms are filed by applicable large employers (employers with 50 or more full-time or full-time equivalent employees).
Form 1095-C must be distributed by by January 31, 2016. Employers must transmit Form 1094 to the IRS by February 29, 2016 for paper filings and by March 31, 2016 for electronic submissions.
The final Instructions are very similar to the draft instructions released earlier this year. See our article here.
Two major clarifications in the final Instructions include:
- Coverage in More than One Type of Minimum Essential Coverage. The instructions clarify that if a coverage provider offers more than one type of minimum essential coverage to an individual, only one type of coverage has to be reported. For example, an employer that has a self-funded medical plan and an HRA can report on the medical plan, only.
- COBRA Reporting. If COBRA is offered to a former employee upon termination of coverage, this is not reported as an offer of coverage on Line 14 of Form 1095-C. Instead, the applicable large employer will report no offer of coverage (Code 1H) and indicate that the individual is not employed on Line 16 (Code 2A).
Other items were clarified in the final documents. BAS has reviewed the final Forms and Instructions and is prepared for 2015 health care reform reporting. For more information about BAS’ health care reform data collection and reporting module, contact solutions@BASusa.com.