On August 28, the Internal Revenue Service released draft instructions
to two forms that large employers will use to report information required by the Affordable Care Act’s (ACA’s) “employer mandate.” The draft forms themselves had been released on July 24.
Under the ACA’s new reporting requirements, implemented by Sections 6055 and 6056 of the Internal Revenue Code, large employers must provide information to the IRS about the health plan coverage they offer to their employees beginning in calendar year 2015. Forms filed electronically will be due on March 31, 2016. Summary information will be reported on Form 1094-C (“Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns”) and information about each employee will be reported on Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”).
The mandate will apply to employers with 50 or more full-time (or full-time equivalent) employees. Until the instructions were released, businesses would have had a difficult time setting up their computer systems to comply with the mandate’s reporting rules with only the draft forms for guidance. “Filling out the forms without instructions is kind of like putting a piece of furniture together without the guide,” said Neil Trautwein, vice president at the National Retail Federation.