Highlights
PURPOSE OF § 6055 REPORTING
- This additional reporting is intended to promote transparency in health plan coverage and costs.
- It will also provide the government with information to administer the individual mandate, which became effective in 2014.
FORMS USED FOR REPORTING
- Entities that are reporting under Section 6055 generally will use Form 1094-B and Form 1095-B.
- Entities that are reporting under both Sections 6055 and 6056 (ALEs that sponsor self-insured plans) will use a combined reporting method on Form 1094-C and Form 1095-C.
Provider Reporting of Health Coverage — Code Section 6055
The Affordable Care Act (ACA) created reporting requirements in Internal Revenue Code (Code) Section 6055. Under these rules, all entities that provide minimum essential coverage (MEC) must report information to the Internal Revenue Service (IRS) about the health plan coverage they provide. Related statements must also be provided to individuals covered by the MEC.
Reporting was first required in early 2016 for calendar year 2015. For the 2018 calendar year:
- Returns must be filed no later than Feb. 28, 2019, or April 1, 2019, if filed electronically; and
- Individual statements must be furnished by March 4, 2019.
OVERVIEW
The Section 6055 reporting requirements apply to all providers of MEC. Generally, the following entities are responsible for reporting under Section 6055:
- Health insurance issuers, for insured coverage;
- Plan sponsors of self-insured coverage (however, a self-insured plan sponsor that is also an applicable large employer (ALE) will use Forms 1094-C and 1095-C, instead of Forms 1094-B and 1095-B); and
- Governmental units that provide coverage under a government-sponsored program.
These reporting entities must report information about each individual who was covered under the MEC they provided during the year.
DEADLINES FOR INFORMATION REPORTING
The required forms generally must be filed with the IRS annually, no later than Feb. 28 (March 31, if filed electronically) of the year following the calendar year to which the return relates. Due to a delay, for the 2015 calendar year, returns were required to be filed no later than May 31, 2016, or June 30, 2016, if filed electronically. For the 2016 calendar year, returns were required to be filed no later than Feb. 28, 2017, or March 31, 2017, if filed electronically. For the 2017 calendar year, returns must have been filed by Feb. 28, 2018, or April 2, 2018 (March 31, 2018, being a Saturday), if filed electronically.
For the 2018 calendar year, returns must be filed by Feb. 28, 2019, or April 1, 2019 (March 31, 2019, being a Sunday), if filed electronically.
Each reporting entity must also furnish statements annually to individuals who are provided MEC, generally on or before Jan. 31 of the year immediately following the calendar year to which the statements relate. Due to a delay, for the 2015 calendar year, individual statements must have been furnished no later than March 31, 2016. For the 2016 calendar year, IRS Notice 2016-70 extended the due date for furnishing 2016 Forms 1095-B and 1095-C to individuals to March 2, 2017. For the 2017 calendar year, IRS Notice 2018-06 extended the due date for furnishing 2017 Forms 1095-B and 1095-C to individuals to March 2, 2018.
For the 2018 calendar year, individual statements were required to be furnished by Jan. 31, 2019. However, the IRS has extended the due date for furnishing 2018 Forms 1095-B and 1095-C to individuals. Specifically, Notice 2018-94 extended the due date for furnishing the 2018 Forms 1095-B and 1095-C to individuals to March 4, 2019.
Extensions may be available in certain circumstances. However, an alternate deadline is generally not allowed for employers with non-calendar year plans. Although employers may collect information on a plan year basis, employees will need to receive their individual statements early in the year in order to have the requisite information to correctly and completely file their income tax returns for that year.
LINKS AND RESOURCES
- On March 5, 2014, the IRS released final regulations on the Section 6055 reporting requirements.
- In addition, the IRS issued Q&As on Section 6055 reporting and a brochure to aid compliance.
- 2016 Forms 1094-B and 1095-B, along with related instructions became available on Sept. 26, 2016.
- IRS Notice 2015-68 and proposed regulations (published on Aug. 2, 2016) provide additional guidance on Section 6055 reporting.
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