The IRS released final Forms and Instructions for the 6055/6056 reporting required under health care reform. IRS forms 1094-C, 1095-C, 1094-B and 1095-B, along with instructions, were finalized for employers who wish to voluntarily report 2014 coverage information.
Employers are not required to report health care reform data for 2014; however, employers may do so voluntarily. No employer pay-or-play penalties will be assessed for 2014, regardless of whether an employer voluntarily files or not.
The 2014 final forms are identical to the draft forms released last year. The instructions are very similar, but provide a bit of extra explanation. They also clarify that employers may report coverage for non-employees (retirees, COBRA participants) on Form 1094-C or 1094-B, at the employers discretion.
Purpose of the Forms
The C Series forms are used by employers with 50 or more full-time employees to report information about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C is used to report summary information for each employer and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee. Employers that offer self-insured coverage also use Form 1095-C to report information to the IRS and employees about whether the coverage offered was minimum essential coverage.
The B series of forms are used by every entity that provides minimum essential coverage. Health insurance issues or carriers will file Form 1095-B for insured employer coverage, as will small employers with self-funded coverage.
Summary of Form Requirements
An applicable large employer with 50 or more full-time equivalent employees that offers minimum essential coverage to an individual for a calendar year must provide an informational return to the employee (1095-C) and a transmittal to the IRS (1094-C) A small employer with a self-funded plan has to provide an informational return to the employee (1095-B) and an informational return to the IRS (1094-B).
The following is a summary of what Form is used by each plan:
1095-B (return- goes to covered individual and filed with IRS along with Transmittal Form 1094-B)
- Small employers (less than 50 employees during prior calendar year) with self funded plans
- Insurance company for insured plans- no matter what size
- Sponsors of multi-employer plans
1095-C (return- goes to covered individual and filed with IRS along with Transmittal Form 1094-C)
- Employer with 50 or more FTEs during prior calendar year
1094-B (transmittal form to IRS)
- Insurers of fully-insured plans will use this as the transmittal to the IRS
1094-C (transmittal form to IRS)
- Employers with 50 or more FTEs during prior calendar year will use this as the transmittal to the IRS
Benefit Allocation Systems, Inc. is prepared to assist employers with the complex health care reform reporting and transmittal requirements. For more information, contact solutions@basusa.com.
