PPACA and the IRS:
Final Tax Forms and Reporting Guidance for Employers
With the 2015 tax season looming, we have received finalized tax forms and reporting guidance from the IRS on 2/8/2015. These forms and guidance will be applicable for employers who offer health insurance benefits and health insurance carriers under Internal Revenue Code Section 6055 and Section 6056. Here are the applicable forms for your review/download:
Form 1094 - B
Form 1095 - B
Form 1094 - C
Form 1095 - C
The agencies also released final transmission forms that will be used to submit the information to the IRS. The IRS initially released the draft tax forms on July 24, 2014, and the draft instructions on August 28, 2014. The final forms and instructions are largely consistent with draft forms and instructions released last summer. Instructions for electronic filing of the information returns are under development, but employers who file at least 250 forms annually will be required to file electronically.
Under section 6056, employers must provide information to the IRS and employees about coverage that employers offer to employees. Section 6055 requires employers who offer self-insured plans and insurers to report to the IRS information on individuals enrolled in coverage, including employee and dependent Social Security numbers. However, the final instructions for forms 1094-B and 1095-B clarify that health insurers may provide taxpayer identification numbers (TINs) for covered individuals who do not have Social Security numbers.
Employers must collect information about the coverage period beginning January 1, 2015, the effective date of the employer mandate. Information returns will be filed for the first time in 2016. The final regulations apply the same filing schedule used for Forms W-2 and 1099 to the section 6055 and 6056 reporting. The rules provide that section 6055 and 6056 returns must be filed annually with the IRS by March 31 if filing electronically (or by February 28 otherwise) of the year immediately following the calendar year to which the return relates. Statements to employees must be provided annually by January 31.