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IRS Issues Drafts of Instructions for Employer and Individual Responsibility Reporting Forms

The Internal Revenue Service (IRS) must verify whether or not individuals have purchased and paid for required minimum essential coverage, whether or not individuals who request premium tax credits are entitled to them, and whether or not large employers are meeting their shared responsibility (play or pay) obligations.  In order for the IRS to do this job, employers and insurers are required to provide reporting on the health coverage they offer. Reporting will first be due early in 2016, based on coverage in 2015.

Although reporting will not begin until 2016, the reporting will reflect coverage offered and elected during the 2015 calendar year (regardless of whether the plan is a calendar year or non-calendar year plan). All sponsors of self-funded plans and all employers with 50 or more employees (whether coverage is self-funded or fully insured) should begin assessing their data gathering and systems soon to be sure they will be able to access and report the needed information when reporting begins. Although the play or pay requirements do not apply to many employers with 50 to 99 employees for 2015, reporting is still required for 2015 from these employers. This employer reporting will help the IRS administer the individual shared responsibility requirements and eligibility for premium tax credits.

An employer’s reporting obligation varies by its size, its funding method (self-funded or fully insured) and whether it is part of a controlled group. On August 28, 2014, the IRS issued draft instructions for completing the forms; drafts of the actual forms were issued on July 24, 2014. The IRS has said that the final forms and instructions will be available by the end of 2014. While there will probably be a few changes between the draft and final versions of the requirements, the reporting requirements are becoming clear enough for employers to begin planning to meet this requirement. For more information download our PPACA Advisor.

Robert Recchia 9/24/14

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