Two sets of recently updated Q&As from the Internal Revenue Service (IRS) provide guidance on the information reporting requirements under the Affordable Care Act (ACA). One set of Q&As(click to reference) relates to information reporting by health coverage providers under Internal Revenue Code (IRC) section 6055, and the other set of Q&As (click to reference) relates to reporting on offers of health insurance coverage by employers under IRC section 6056.
ACA Information Reporting Basics
The ACA requires insurers, self-insuring employers, and other parties that provide minimal essential health coverage (MEC) to report information on this coverage to the IRS and to covered individuals (“section 6055 reporting”). Large employers (generally those with 50 or more full-time employees, including full-time equivalents) are also required to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered (“section 6056 reporting”).
Both sets of Q&As make clear that information reporting under sections 6055 and 6056 is voluntary for calendar year 2014. Therefore, the first section 6055 and 6056 returns required to be filed are for the 2015 calendar year and must be filed no later than February 29, 2016 (or March 31, 2016, if filed electronically).The Q&As also provide information regarding what information is required to be reported, and how to report the required information, among other things.
In order to fulfill your reporting requirements, we encourage you to plan now on how you will capture and maintain the required information necessary to comply by the filing deadline.