The IRS issued final regulations regarding the employer reporting procedures of the ACA almost a year ago (March 2014). However, employers and advisors have been waiting on pins and needles for the final forms and instructions to be released.
Final Forms 1094-C and 1095-C were released on February 9, 2015. And not a moment too soon, as Applicable Large Employers (ALEs) must file these reports for 2015.
What are Forms 1094-C and 1095-C? What does "6055" and "6056" Even Mean?
“6055” and “6056” refer to the Internal Revenue Code Sections that give the Affordable Care Act (ACA) its teeth. Section 6055 relates to enforcement of the individual mandate, while Section 6056 relates to enforcement of the employer shared responsibility provisions of the law.
Compliance data will be transmitted via Forms 1094 and 1095. In a nutshell – Form 1094 is a transmittal designed to summarize the detailed Forms 1095 that accompany the transmittal. Think of them the same way you think of W-3s and W-2s that you generate each year. The 1094 and 1095 reports are due the same time as W-3s and W-2s, so there’s a natural connection!
The “A”, “B” and “C” extension for each form tells us who is responsible to file them:
Form A will be filed by government entities such as public exchanges (i.e., Covered California)
Form B will be filed by health insurers (like Anthem or Blue Shield) and self-funded employers
Form C will be filed by all Applicable Large Employers
Meaning that most affected employers will only need to concern themselves with Forms 1094-C and 1095-C.
Are You Ready?
While reporting was optional for 2014, it is not for 2015. Do you have a firm grasp of your reporting obligation? Are you currently capturing the data that you will need to report? Vita will be hosting informative webinar sessions to simplify the complexities of these reporting requirements and to help you understand what you need to do to stay compliant.
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