The Affordable Care Act added section 6056 to the IRS code requiring that applicable large employers (ALEs) file annual reports detailing the terms and conditions of health coverage provided to full-time employees. It also added section 6055 to require similar annual reporting by insurers, self-funded plans and other entities that provide minimum essential coverage (MEC). This information is needed so the IRS can verify employer-sponsored coverage and evoke the pay-or-play penalty if necessary.
Forms 1094-B, 1095-B, 1094-C and 1095-C are still in draft form – do not file these forms. Remember that these forms do not have to be filed until early 2016 for the 2015 plan year. Get the draft forms.
Form 6055, or the MEC form, requires the issuer to report the number of months the MEC plan was in place. It’s required for all plans, regardless of size – even small group.
Form 6056 is to be filed by all ALEs. Generally this form notifies the IRS of all full-time employees and dependents, what months they were covered and the employees’ share of the lowest cost monthly premium for self-only coverage.
There are penalties of $100 per return not filed, not to exceed $1.5 million. If you haven’t checked into a tracking system, this renewal cycle would be a great time to start those conversations with your insurance advisor . A quick reference guide, provided by Thomson Reuters, gives you an easy way to view the forms and deadlines.
If you have any questions about the ACA or employee benefits, contact your broker.