In early February, the IRS released final Forms and Instructions for Information Reporting under the Affordable Care Act. This included Final Forms and Instructions for 1094-B, 1095-B, 1094-C and 1095-C.
As we discussed in a prior episode, information reporting requires applicable large employers (defined as employers with 50 or more full-time or full-time equivalent employees) to file with the IRS information about the health coverage that they provide to their employees. The IRS then reviews this information in order to determine compliance with the Individual Mandate and the Employer Shared Responsibility requirements of the Affordable Care Act.
While the Final B Forms, the Final C Forms, and the Final B Form Instructions are nearly identical to the Draft Forms and Instructions that were released in late Summer of 2014, the Final Instructions for the C Forms do provide important clarifications.
Among these clarifications, perhaps one of the most important, and most welcomed by employers, is one that is applicable to employers that sponsor self-insured group health plans.
The draft Instructions required such employers to use the B Forms for filing enrollment information about non-employees (including non-employee directors, COBRA qualified beneficiaries and retirees).
In contrast, the Final Instructions clarify that such employers are allowed to use either the B Forms or the C Forms for filing such enrollment information. This will allow these employers to complete all of their information reporting requirements on the C Forms without having to bother with the B Forms at all.
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