Employee Benefits Compliance, Large Employers, Reporting Requirements

IRS Releases 2015 Draft Forms 1094 and 1095 for Information Reporting

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On June 16, 2015, the IRS released draft versions of 2015 forms 1094 and 1095 that employers will use to report what health plan coverage they offered or provided to employees.  This information reporting is required under Internal Revenue Code Sections 6055 and 6056. These 2015 draft forms are largely unchanged from the 2014 versions, except for a few minor changes noted below.

These 2015 forms and instructions are draft versions only and should not be filed with the IRS or relied upon for filing. The IRS may make changes prior to releasing final 2015 versions.  The IRS has not yet released instructions to the 2015 forms.

Background

The Affordable Care Act (ACA) created new information reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) or provide to their employees. Reporting is first required in the first quarter of 2016, related to coverage offered or provided in 2015. The IRS previously released final 2014 versions of the reporting forms on Feb. 8, 2015, as well as line-by-line instructions, separate Q&As on Code section 6055 and 6056 reporting and Q&As on Employer reporting using Forms 1094-C and 1095-C.  See links to these at the end of this article 2015 Draft Forms – Changes from 2014 Forms The 2015 draft forms just released include the following minor changes from the 2014 versions:

  • Form 1095-C – 2015 form includes an additional field, titled “Plan Start Month.” This new field is optional for 2015, but will be required for 2016 and beyond. For 2015, ALEs can choose to:
    • Add this field and provide plan year information;
    • Add this field and enter “00”; or
    • Not include this new field (i.e., use the 2014 format).
  • Forms 1095-B and 1095-C- 2015 forms include a “Continuation Sheet” that filers will use if they need to report coverage information for more than six individuals.
  • Form 1094-C – 2015 form moved Line 19 (regarding the authoritative transmittal) to be included in Part I.  In 2014 version, line 19 was included as the first line of Part II.
  • Form 1094-C– 2015 form seems to allow information to be entered in the “All 12 months” box in Part III, Column (b): Full-Time Employee Count for ALE Member (this box is no longer grayed).
  • Forms 1095-B and 1095-C – 2015 forms no longer include an “Instructions for the Recipient” page. However, it’s possible this could be added back into the final versions of the 2015 forms.

In addition, according to a note on the 2015 draft Form 1095-C, the IRS intends to include two additional “Offer of Coverage” codes for 2016 and beyond. On the 2015 forms, the “Offer of Coverage” codes will remain unchanged for 2015. In 2016 and beyond, the IRS intends to include these additional codes, which an employer would use (if applicable) to indicate that the employer’s offer of coverage to an employee’s spouse is a conditional offer.

Links to Prior and Updated IRS Guidance