Earlier this year, the Department of Treasury released long-awaited regulations on the Patient Protection and Affordable Care Act’s health coverage information reporting requirements. Beginning in 2016 (for information relating to 2015), employers must report information about health coverage provided during the prior year to all enrollees, as required by IRC Section 6055 (minimum essential coverage reporting). This information includes taxpayer identification numbers of all covered persons, as well as the specific dates that covered persons had health coverage.

In addition, employers with 50 or more full-time employees must report information about health coverage offered during the prior year to full-time employees, including information about the lowest cost option offered and whether the minimum value requirements were satisfied, as required by IRC Section 6056 (employer responsibility reporting). The regulations specify that information will be reported on Form 1094-C, which is the transmittal form, and Form 1095-C, which is the employee statement. While a separate employee statement is required for each full-time employee, employers may submit a single transmittal for all returns filed for the calendar year. Additionally, employers with 250 or more W-2s are required to submit the Forms electronically. Draft Forms 1094-C and 1095-C are expected to be released by the IRS as the reporting deadline approaches.

By Destyn D. Stallings, dstallings@dsda.com