Employer Reporting – Final Forms Available

The IRS has issued final forms and instructions for employer reporting and notices relating to insured health plan coverage. The final versions are largely unchanged from the prior draft versions. The forms will be used to enforce Affordable Care Act employer penalties and individual mandate and tax credit eligibility rules with mandatory reporting starting in 2016 for the tax year 2015. Large employers with 50 or more full-time employees (including full-time equivalents) are required to complete these forms.

Form 1094-C is the Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. This form is used to report aggregate employer level data on each employee. Form 1094-C is providing summary information for each employer, and each employer will submit this form to the IRS.

Form 1095-C is the Employer-Provided Health Insurance Offer and Coverage. Form 1095-C will be submitted to the IRS AND will be provided to each employee as it includes information about the health insurance offered to them. This form must be filed for everyone who was a full-time employee of the employer for any month of the calendar year.

Attached are the final version of Forms 1094-C and 1095-C.

Both Finance Manager (FM) and WinCap are aware the IRS has provided final forms. Tim Keller at Genesee Valley/Wayne-Finger Lakes Educational Technology Service has let Smola Consulting know neither organization has released the modules that will support the completion of these forms. He is expecting them soon.

Per the IRS Final Instructions (http://www.irs.gov/pub/irs-pdf/i109495c.pdf):

• You must file Forms 1094-C and 1095-C by February 28 if filing on paper or March 31 if filing electronically of the year following the calendar year to which the return relates.
• For calendar year 2015, Forms 1094-C and 1095-C are required to be filed by February 29, 2016, or March 31, 2016, if filing electronically.

More information can be found at:

http://www.irs.gov/pub/irs-pdf/f1094c.pdf

http://www.irs.gov/pub/irs-pdf/f1095c.pdf

http://www.irs.gov/pub/irs-pdf/i109495c.pdf

This information does not constitute legal advice.  Employers should consult their own legal counsel with respect to compliance with these laws.