Health Care Reform Reporting Requirements: Final Rules

The Patient Protection and Affordable Care Act (PPACA) contains requirements for both individuals and employers related to health care coverage. In order to assure compliance with certain of these requirements, PPACA requires new information reporting to the IRS related to individual and employer group health coverage. In particular, one item the IRS requires is information to confirm that an individual has minimum essential coverage and is not subject to the Section 5000A of the Internal Revenue Code (the "Code") individual responsibility payment. As well, the IRS is seeking information to help it determine if an "applicable large employer" is subject to one of the "pay or play" penalties under Section 4980H of the Code. To that end, on March 5, 2014, the IRS released final regulations governing information reporting under Sections 6055 and 6056 of the Code with respect to health plan coverage. Section 6055, and the regulations thereunder, provide guidance on reporting