Under the new regulations from the IRS, employers will be required to report on the health care coverage they are offering their employees. Employers who self-insure and are large enough (50 or more full time employees) to be subject to the employer responsibility  provisions will complete both Section 6055 and Section 6056. Those employers that are subject to employer responsibility but do not self-insure will only complete Section 6056. Employers will be required to report to the IRS as well as their own employees.

For Section 6056 reporting, applicable large employers must provide their name, address and employer identification number as well as the name and phone number of a contact person. The employer must also certify whether it offered its full-time employees the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan and which months that it was available. The employer must also disclose what each employee’s share was of the lowest-cost monthly premium for employee-only coverage. Additionally, an employer must also provide the names, addresses and taxpayer identification numbers of each full time employee during the calendar year and which months, if any, the employee was covered.

An employer can use indicator codes rather than detailed explanations on the reporting form to indicate the following:

•Whether the coverage offered met minimum value and whether the employee had the opportunity to enroll a spouse in the coverage
•The total number of employees, by month
•Whether an employee’s effective date of coverage was affected by a permissible waiting period, by month
•Whether there were any months during which no employees were providing services or otherwise being credited with any hours of service for the employer
•Information regarding controlled group status and, if applicable, the name and EIN of each employer member of the controlled group on any day during the calendar year
•If a third party is doing the reporting for an employer, the name, address and tax identification number for that third party must be submitted as well.

Employers should also use indicator codes on the form to report the following information about each full-time employee for each month:

•Whether minimum essential coverage meeting minimum value was offered to the employee only, the employee and the employee’s dependents only, the employee and the employee’s spouse only, or the employee and the employee’s spouse and dependents
•The justification for not offering coverage to the employee, if any
•Whether coverage was offered to the employee for the month, even though the employee was not a full-time employee during that month
•Whether the employee was covered under the plan
•Whether the applicable large employer met one of the affordability safe harbors with respect to the employee

Since employers are required to report a large amount of information, there is also a simplified filing method available which means employers can report annually rather than on a monthly basis. To qualify, an employer must make a qualifying offer to all full-time employees for a full year. An employee’s contribution cannot be more than $1100 for the year for employee-only coverage and must also include an offer to the employee’s spouse and dependents. An employer that can certify that a qualifying offer was made to at least 95% of its full time employees can take advantage of simplified filing.

Under Section 6056, employers must also provide information to their employees. Employers should include their name and contact information as well as the information that they provided in the report to the IRS. Employees may use the statements to help determine whether, for each month of the year, they can claim an individual premium tax credit on their tax returns. These statements must be given to each employee by January 31st of the year following the reporting year.

For more information:
Employer Reporting Responsibility

New Guidance On Information Reporting Requirements Under The Affordable Care Act