IRS Releases Final Regulations on ACA Reporting

March 2017

On Wednesday, March 5, 2014, the Internal Revenue Service (IRS) released final regulations (Final Regulations) on two reporting requirements under the Affordable Care Act (ACA) effective in 2015.

The ACA added Sections 6055 and 6056 to the Internal Revenue Code (Code). Code § 6055 requires reporting by all entities that provide insurance (insurance companies, self-insured employers, governmental entities and others) which is filed with the IRS and given to the individuals to whom they provide "minimum essential coverage" (MEC). Code § 6056 reporting is filed with the IRS and given to individuals and is used to report whether applicable large employers-those with 50 or more full-time employees, including full-time equivalents (FTEs)-offered coverage to their full-time employees that meets the affordability requirements of the ACA's pay-or-play mandate.

The IRS released proposed regulations (Proposed Regulations) last year. The Final Regulations largely follow the Proposed Regulations but also simplify the proposed rules for both employers and issuers. A single, combined form is available for self-insured employers, which are generally subject to both reporting requirements. Large employers with fully insured group health plans will complete only the top half of the form for Code § 6056 reporting, while the insurance company will complete a separate form to satisfy its Code § 6055 obligation. The rules are particularly streamlined for employers that make highly affordable coverage available to employees, including an offer of coverage to their spouses and dependents.

To learn more about the impact of this and other health care reform decisions, please visit Peel & Holland University, where we have posted a document titled IRS Releases Final Regulations on ACA Reporting.  



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