IRS Releases Forms, Instructions for 2016 Reporting of Health-Care Coverage Under ACA

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By Michael Trimarchi and Kurt Naasz

The forms and instructions that employers are to use in reporting health coverage offered to employees in 2015 under the Affordable Care Act were released Sept. 16 by the Internal Revenue Service.

The forms for the first required mandatory filing in 2016 are:

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage;

Form 1095-B, Health Coverage;

Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and

Form 1094-B, Transmittal of Health Coverage Information Returns.

Instructions for the B and C series of forms also were released.

For tax year 2015, employers are to file paper forms by Feb. 29, 2016, or March 31, 2016, if filing electronically, the instructions said.

Forms 1095-C and 1095-B were revised to include continuation sheets for use when there are more than six covered individuals, the IRS said.

Forms 1095-C are due to individuals by Feb. 1, 2016, the IRS said. Filers of Form 1095-B must furnish a copy by Jan. 31, 2016, to the person identified as the responsible individual on the form.

Forms 1094-C and 1095-C are used to report employee eligibility for employer-provided health care coverage, employer offers of coverage to eligible workers and the minimum value amounts of the health plan under the ACA. Insured applicable large employers with at least 50 full-time equivalent employees are to file Parts I and II of Form 1095-C. Self-insured applicable large employers with at least 50 full-time equivalent employees are to complete Parts I, II and III of Form 1095-C.

Bracing for Possible Sticker Shock From Third-Party Processors

Fulfilling these new reporting requirements will be harder for some employers than others, said David Lewis, president and chief executive officer of Operations Inc., a human resources outsourcing and consulting company in Hartford, Conn.

The process of gathering and reporting the required information is likely to be more challenging for employers that do not have a payroll-service provider, are not using electronic recordkeeping or timekeeping systems or have high employee turnover or seasonal workers, Lewis said.

“The more variables they have, the more complicated it’ll be,” Lewis said.

On the other hand, Lewis said, if employers have good technology and already have the necessary data collected in an electronic format, the process can go much more smoothly.

Payroll professionals also should prepare for possible sticker shock when asking third-party service providers to perform ACA-reporting tasks, he said.

“In some cases, cost can be an issue if the ACA reporting component is part of a larger data management package that must be paid for on top of regular payroll processing,” Lewis said.

To contact the reporters on this story: Michael Trimarchi in Washington at mtrimarchi@bna.com and Kurt Naasz at knaasz@bna.com.