Draft Instructions For ACA Reporting Forms Released

The IRS has released draft instructions for Forms 1095-A, 1094-B, 1095-B, 1094-C and 1095-C. These forms are used for reporting medical care coverage under the Patient Protection and Affordable Care Act (ACA).

Form 1095-A. Form 1095-A, Health Insurance Marketplace Statement, is used to report information about family members who enroll in a qualified health plan through the Marketplace. It also is furnished to individuals to allow them to claim the premium tax credit. Health Insurance Marketplaces must file Form 1095-A to report information on all enrollments in qualified health plans through the Marketplace. Marketplaces may be state Marketplaces, regional Marketplaces, subsidiary Marketplaces, or the federally-facilitated Marketplace. Form 1095-A must be filed with the IRS and furnished to individuals on or before January 31, 2015, for coverage in calendar year 2014.

Forms 1094-B and 1095-B. Form 1095-B, Health Coverage, is used to report certain information to the IRS and to taxpayers about individuals who have minimum essential coverage and, therefore, are not liable for the individual shared responsibility payment. The return and transmittal (Form 1094-B, Transmittal of Health Coverage Information Returns) must be filed with the IRS on or before February 28 (March 31, if filed electronically) of the year following the calendar year of coverage. These forms are not required to be filed for 2014. However, in preparation for the first required filing of these forms in 2016, reporting entities may voluntarily file in 2015 for 2014 in accordance with the instructions. The draft forms and instructions are available here: http://www.irs.gov/pub/irs-dft/i109495b–dft.pdf.

Forms 1094-C and 1095-C. Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is used by employers with 50 or more full-time employees to report the information required under Code Sec. 6055 and 6056 about offers of health care coverage and enrollment in health care coverage for their employees. Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, must be used to report to the IRS summary information for each employer and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee. Forms 1094-C and 1095-C are not required to be filed by any employer for 2014. However, in preparation for the first required filing of these forms, employers may voluntarily file in 2015 for 2014 in accordance with the instructions. The draft forms and instructions are available here: http://www.irs.gov/pub/irs-dft/i109495c–dft.pdf.

No employer shared responsibility payments under Code Sec. 4980H will apply for 2014 for any employer, regardless of whether they voluntarily file for 2014. For more information on transition relief from the reporting requirements and employer shared responsibility payments for 2014, see Notice 2013-45.

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