Draft Instructions for Employer Reporting of Health Coverage Released

Last week we posted the draft forms for employer reporting of health coverage.  These forms are required for most applicable large employers under the Affordable Care Act.  Now, the instructions for these forms have been made available.

Draft Instructions for Employer Reporting of Health Coverage Released

The bulletin below has more information regarding the instructions.  For just the instructions themselves, click below.

These can be complicated issues, so if you need assistance, please do not hesitate to contact us.

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IRS Releases Draft Forms for Employer Reporting of Health Coverage

In July the Internal Revenue Service (IRS) released draft versions of forms that employers will use to report information under Sections 6055 and 6056 about the health insurance coverage they provide to their employees.  These forms are draft only and should not be filed with the IRS.

The following draft forms are available, and can be found here.

  • Form 1094-B: Transmittal of Health Coverage Information Returns;
  • Form 1095-B: Health Coverage;
  • Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return;
  • Form 1095-C: Employer-Provided Health Insurance Offer and Coverage

Forms 1094-C and 1095-C will be used by large employers that are reporting under Code Section 6056.  Forms 1094-B and 1095-B will be used by health insurance insurers/carriers, self-insured plan sponsors that are not large employers, multiemployer plan sponsors, and providers of government sponsored coverage under Section 6055.  But be careful, because a reporting entity that is reporting under 6055 as a large employer will file under a combined reporting method, using forms 1094-C and 1095-C.

Instructions for the forms can be found here.

For more information, take a look at the bulletin below, and feel free to contact us.

IRS Releases Draft Forms for Employer Reporting of Health Coverage

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Final Rule Released on ACA Waiting and Orientation Periods

On June 23, 2014, final rules regarding the Affordable Care Act’s (ACA) Waiting Period and Orientation Period were announced.  The ACA says that groups and health insurers offering group coverage cannot apply any waiting period longer than 90 days.  The final rule clarifies the maximum length of any “reasonable and bona fide employment-based orientation period” as it relates to the waiting period limit.

This rule will go into place on January 1, 2015.  Read more details in the Health Care Reform Bulletin below.

Final Rule Released on Waiting and Orientation Periods

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IRS Increases Affordability Percentage Under Employer Mandate for 2015

One of the compliance pieces of the Patient Protection and Affordable Care Act (PPACA) that has had an impact on how employer sponsored plans are designed is whether or not a plan is considered “affordable.”  Since the plan’s passage, affordable has meant that an employee contribution be no higher than 9.5% of the employee’s household income for the year.  For a single person with a federal minimum wage position, this equals roughly $89-90 per month.

On July 24, 2014 the IRS released Revenue Procedure 2014-37 to index the PPACA’s affordability percentages for 2015.  Beginning on January 1, 2015 the affordability percentage will be 9.56%.  This will not have a major impact on the affordability of a plan, but is worth noting.

There are several safe harbors that employers may consider when it comes to determining if their plan is affordable.  These, and other useful information, can be read in the bulletin below.

IRS Increases Affordability Percentage under Employer Mandate for 2015

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Federal Courts Issue Conflicting Rulings on Subsidies in Federal Exchanges

On July 22, 2014, two federal appeals courts—the District of Columbia Circuit Court and the 4th U.S. Circuit Court—issued inconsistent rulings on the availability of subsidies in states with FFEs.

In the more prominent of the two (because of the potential ramifications to the Affordable Care Act), the D.C. Circuit Court ruled in a 2-1 opinion that the IRS cannot authorize subsidies in states that use federally funded exchanges.

However, the 4th Circuit Court unanimously upheld the availability of the ACA’s subsidies in states that use federally funded exchanges.

You can read more about the rulings and their impact on employers in the bulletin below.

Federal Courts Issue Conflicting Rulings on Subsidies in Federal Exchanges

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