The Internal Revenue Service recently released draft versions of the forms that will be used to meet the
The issuance of these forms has been much anticipated since the Treasury Department issued tax regulations on the reporting requirements for both the
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The forms aim to fulfill the reporting requirements as follows:
6055 COMPLIANCE | 6056 COMPLIANCE |
Health insurance issuers, sponsors of self-funded health plans, and other entities that provide minimum essential coverage must file: | Applicable large employers that employed an average of at least 50 full-time employees (including full-time equivalents) on business days during the preceding year must file: |
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Special Rule: As part of an effort to streamline the reporting process, applicable large employers that sponsor self-funded health plans are to report the information required of them for both the individual and employer mandates on a single combined form using Form 1095-C. Substitute forms will be permitted if they include all of the content required by the prescribed forms and meet other IRS requirements.
Employers will need to update their recordkeeping systems to gather efficiently the month-by-month information required under the shared responsibility reporting requirements for the 2015 calendar.
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As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the ACA.
If you have questions about the draft forms released by the IRS or the shared responsibility reporting requirements, please contact Brian M. Pinheiro at 215.864.8511 or
Jonathan M. Calpas is an associate at Ballard Spahr, where he represents for-profit, tax-exempt, church, and government employers on matters related to tax-qualified retirement plans and health and welfare plans. Edward I. Leeds, a Ballard Spahr counsel, concentrates on issues relating to the design, administration, and taxation of health and other welfare benefits plans.