On August 28, 2014, the IRS issued draft instructions (http://www.irs.gov/pub/irs-dft/i109495b–dft.pdf) for the forms that will be used by insurance companies and employers to report health coverage information under the Affordable Care Act (ACA). The forms will be required to be filed by those employers having over 100 FTE employees as of December 31, 2014. (Read my earlier blog Will You Be Impacted by the Affordable Care Act, and If So, When?)
The new forms (IRS Form 1094-B and C and 1095-B and C) are information returns only, and will reflect ACA information for the 2015 year. IRS Form 1095 basically provides the IRS with information about the level of insurance offered to employees and the employees who were eligible to select the insurance. This form must be filed by February 28, 2016 (March 31, 2016 if filed electronically). Additionally, IRS Form 1094 must be issued to each eligible employee by February 1, 2016.
The IRS indicated that the forms will be finalized later in 2014, but we are not expecting any significant changes to them. Employers should contact their insurers and/or third party administrators to begin the process of coordinating form preparation and issuance to employees.
This is a very general discussion of the ACA rules; there are many exceptions to the above discussion. We would be pleased to assist you in determining the impact of ACA on your company; we can help determine if you are subject to the ACA, and devise strategies for minimizing its impact. For more information on this topic, contact me in our Compensation & Benefits Advisory Services group at 440-449-6800 or email firstname.lastname@example.org.
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