IRS Releases Final Forms For Health Care Reform Reporting

With required reporting under the Affordable Care Act (ACA) looming, employers should be aware of the latest guidance from the IRS. As a reminder, information reporting requirements apply to all employers who are members of an "Applicable Large Employer" under the ACA, generally an employer with 50 or more full-time and full-time equivalent employees in the previous year (including employees of related companies), and small employers that self-insure coverage. The IRS recently released final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C. The first required filing for these forms occurs in January 2016 with respect to coverage for 2015.

Background

As employers have no doubt discovered by now, complying with the ACA reporting requirements is a complex task. In general, every provider of "minimum essential coverage" to an individual must file an information return reporting the coverage. In general, insurers will use Form 1094-B to submit Forms