Beginning in 2015, the Affordable Care Act (ACA) will require employers to report information to the Internal Revenue Service (IRS) as well as their own employees on the health coverage they offer. Recently, final regulations were released on the reporting that aims to streamline the process and provide a simplified option for employers. Additionally, rules were released to provide reporting guidance for insurers and other parties that provide health coverage under ACA. These requirements were delayed a year by the IRS but now employers will be expected to collect data for 2015 and report in 2016.
Under the newly added Section 6055 of the Internal Revenue Code, it is required that employers and insurers report information about the entity providing coverage and include contact information and a list of individuals with identifying information and the months they were covered. Under Section 6056, entities must report information about the applicable large employer offering coverage and provide a list of full-time employees and information about the coverage offered to each, by month, including the cost of employee only coverage. Employers who self–insure and are large enough to be subject to the employer responsibility provisions will complete both sections. Employers who are subject to employer responsibility but do not self-insure will only complete Section 6056. Insurers and other health coverage providers will only report under Section 6055.
In an effort to simplify the reporting process, employers that make an offer of minimum value coverage to their employees for a full 12 months will only need to report identifying information for those employees and acknowledge that they did in fact receive such coverage. For those employees that received an offer of minimum value coverage for less than 12 months, the employer only needs to report the offer was made. Additionally, employers have the option to avoid identifying which employees are full-time only if they can certify that affordable, minimum value coverage was offered to at least 98 percent of the employees on whom it is reporting.
With six months to go until these regulations begin, now is the time to start preparing and making sure you fully understand the regulations and what data is to be collected and reported. It should be noted that the IRS will not impose penalties for incorrect or incomplete information for the 2015 reporting year on employers that have made a good faith effort to comply. 96 percent of all employers are not subject to these ACA reporting requirements or employer responsibility due to their size (fewer than 50 full-time employees) which leaves four percent to which these rules apply.
Additional information:
New ACA Information Reporting Starts for Employers in 2015