ACA Reporting of Healthcare Coverage
Section 6055 and 6056
The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056, which require certain employers to provide information to the Internal Revenue Service (IRS) about the health plan coverage they offer (or do not offer) to their employees.
6056 - Applicable Large Employer Health Coverage Reporting (Code § 6056)
Requires applicable large employers to file information returns with the IRS and provide statements to their full-time employees about the health insurance coverage the employer offered. For more information visit: http://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-o...
6055 - Provider Reporting of Health Coverage (Code § 6055)
Provides that every provider of minimum essential coverage will report coverage information by filing an information return with the IRS and furnishing a statement to individuals. For more information visit: http://www.irs.gov/Affordable-Care-Act/Questions-and-Answers-on-Informat...
More information on these sections
Updates
There have been a number of updates regarding the ACA's Section 6055 and 6056 reporting requirements. The major developments are outlined below: Sept. 17, 2015: The IRS released final 2015 versions of Forms 1094-B, 1095-B, 1094-C and 1095-C, along with related instructions, that employers will use to report under Sections 6055 and 6056. The final instructions include extensions of time to file and a process to obtain an electronic reporting waiver, as well as important clarifications on the reporting of HRA coverage. Aug. 18, 2015: The IRS finalized Publication 5165, Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters. Any employer that files at least 250 Section 6055 or 6056 returns must file electronically (or obtain a waiver). However, these employers can file the first 250 returns on paper, if they so choose. Reporting entities that file fewer than 250 returns during a calendar year may still file via paper. Electronic filing will be done through the ACA Information Returns (AIR) program, which is slated to become available on Oct. 22, 2015. June 29, 2015: The Trade Preferences Extension Act of 2015 was signed into law, which increased penalties for employers that fail to comply with Section 6055 and 6056 reporting. The adjusted penalty amounts for 2016 are outlined below:
Temporary relief from penalties may be available if employers can show they made good faith efforts to comply with the reporting requirements. Employers should review their information returns and individual statements to promote reporting accuracy. |
Reporting Overview
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Section 6055 |
Section 6056 |
Applies to: |
Providers of minimum essential coverage (MEC) |
Applicable large employers (ALEs) |
Requires reporting entities to: |
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Purpose is to help: |
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IRS administer the employer shared responsibility rules |
Self-funded plan sponsors that are ALEs must report under both sections, but will use a combined reporting method
Reporting Deadlines
Rules effective for 2015 coverage
- 2015 coverage information will be reported in
- 2016 Employers must collect information during 2015
IRS Returns |
Individual Statements |
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Electronic Reporting
IRS Returns
- Electronic filing is required for reporting entities that file 250 or more individual statements per calendar year
- Applies separately to each type of individual return (Forms 1095-B or 1095-C)
- Electronic filing is OPTIONAL for other reporting entities
Individual Statements
- General rule: provide statements on paper by mail to last known permanent address (or temporary address)
- Statements MAY be furnished electronically if consent requirements are met
Required Forms