Compliance Minute | Clarity on the IRS’ Information Reporting Forms

Dan Kuperstein

ComplianceMINUTE | Dan Kuperstein | ERISA Penalties Increase for Form 5500 Violations!
There are two sets of IRS forms—the B Forms and the C Forms—and the information that must be filed with the government depends on whether an employer sponsors a self-insured or fully insured health plan. ERISA Attorney Dan Kuperstein explains that most employers will file the C Forms, that is, the 1094-C and the 1095-C, and other details.

Related Resources:
Instructions for Reporting on Forms 1094-C and 1095-C are available here.
Instructions for Reporting on Forms 1094-B and 1095-B are available here.


Video Transcript: 
[What is the third big development?] The third big development that happened this summer was that the IRS released a lot of information about the 2015 Information Reporting Program.

[What is Information Reporting?] Information reporting is a requirement under the Affordable Care Act that requires employers to file with the IRS information about the coverage that they provide to their employees. The IRS then reviews this information in order to determine compliance with the Individual Mandate and Employer Shared Responsibility requirements of the Affordable Care Act.

[What forms do you need to file?] There are two sets of forms, the B Forms and the C Forms, and the information that must be filed depends on whether the employer sponsors a self-insured or fully insured plan, but generally speaking, most employers will have to file the C Forms, that is, the 1094-C and the 1095-C.

The 1095-C includes information about the coverage provided to each individual full-time employee on a month-by-month basis. A copy of this form is distributed to each employee that was covered by the plan.

The 1094-C is the transmittal form that is filed with the IRS, and it includes information about the employer’s offer of coverage and other information about the employer and affiliated employers.

[What is the deadline?] The filing deadline for the 2015 calendar year is February 29, 2016. January 31, 2016 is the deadline for distributing the forms to employees.

[What else do I need to know about information reporting?] An important thing to know is that even if you are an employer that is not subject to the pay or play requirements until 2016 because you have between 50 and 99 employees and meet the other requirements for this transition relief, you will still be required to do information reporting for the 2015 calendar year.

For more information on this and other topics, please visit our Knowledge Center at corpsyn.com. Thank you.