CHA News Article

IRS Issues Draft Forms and Instructions for Employer Health Insurance Coverage Reporting

The Internal Revenue Service (IRS) recently issued draft versions of the new Forms 1094-B, 1094-C, 1095-B and 1095-C, along with related draft instructions. Reporting is first due in early 2016 for the 2015 calendar year. Entities filing 250 or more forms must submit the reports to the IRS electronically, although details regarding formats are still under development. Note that the draft forms and instructions are helpful for hospitals to use to prepare for the required reporting, but should not be relied upon for filing as the IRS may make additional revisions before releasing the final versions.

Late last year, CHA hosted a webinar focusing on employers’ reporting obligations under the Affordable Care Act.  A recording of that webinar is available for purchase on the CHA website and is useful in explaining the reporting obligations in more detail.  

Employers with 50 or more full-time/full-time equivalent employees who do not offer minimum essential coverage (MEC), or who offer MEC through an insurer, will be required to file Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage” (Parts I and II), with the IRS and each employee. The employer will use Transmittal Form 1094-C, “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns,” to transmit Form 1095-C to the IRS.

Employers with 50 or more full-time/full-time equivalent employees who offer a self-insured plan will be required to file the following forms:

  • Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage” (All Parts), with the IRS and each employee, for each employee covered by the plan at any time during the year regardless of full-time status.
  • Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage” (Parts I and II), with the IRS and each employee, for each employee with full-time status at any time during the year and not covered by the plan at any time during the year.
  • Form 1095-B, “Health Coverage” (Parts I, III, and IV), with the IRS and each primary insured, for each individual covered by the plan at any time during the year who was not an employee at any time during the year (for example, COBRA, pre-65 retiree, surviving spouse).
  • In addition, Transmittal Form 1094-C, “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns,” should accompany Form 1095-C. Transmittal Form 1094-B, “Transmittal of Health Coverage Information Returns,” should accompany Form 1095-B.

Insurers, self-insured plan sponsors, and others that provide MEC will be required to file Form 1095-B, “Health Coverage” (Parts I, III and IV), with the IRS and each primary insured, and will use Transmittal Form 1094-B, “Transmittal of Health Coverage Information Returns,” to transmit Form 1095-B.

The purpose of the forms is to provide the appropriate information to the IRS and the individual to determine whether the individual is required to pay a penalty to the IRS for failure to maintain acceptable health insurance.

Instructions for Forms 1094-B and 1095-B may be found at www.irs.gov/pub/irs-dft/i109495b–dft.pdf
Instructions for Forms 1094-C and 1095-C may be found at www.irs.gov/pub/irs-dft/i109495c–dft.pdf
Additional information may be found at the IRS website at www.irs.gov/Affordable-Care-Act/Employers/Information-Reporting-by-Providers-of-Minimum-Essential-Coverage.

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