2015 Instructions/Forms for IRS Reporting Requirements

2015 Instructions/Forms for IRS Reporting Requirements

UPDATE: Links to final forms are now available. The buttons within this blog have been updated as of 10/13/15. Additional information can be found in our blog post IRS Tax Tip: 2016 Reporting Deadlines for Employers and Health Coverage Providers.

The following information was received from our partner Cigna on 7/31/15 Cigna

On August 7, 2015 the Internal Revenue Service (IRS) released draft instructions and revised draft 1095-B and 1095-C forms to be used for Affordable Care Act (ACA) Minimum Essential Coverage (MEC) and Large Employer reporting in 2016. The IRS has posted the 2015 draft instructions and forms at IRS.gov/draftforms as information only, and will post final versions at a later date.

The revised 2015 draft forms are generally unchanged from the versions released on June 19, 2015. However, the IRS made several changes to the 2014 final instructions, including:

  • “B” form instructions for applicable large employers – The draft instructions for forms 1094-B and 1095-B now allow applicable large employers (ALEs) the option to use the “B” forms to report coverage of individuals who are not considered full-time employees for any month during the calendar year.
  • “C” form instructions for applicable large employers – The draft instructions for forms 1094-C and 1095-C require that ALEs continue to report all employees enrolled in self-insured coverage on the “C” forms – as part of MEC reporting.
  • 30-day extension for IRS filing – An automatic extension is granted if Form 8809 is submitted to the IRS on or before the filing due date.
  • 30-day extension for providing forms to individuals – An extension may be granted by submitting a letter to the IRS on or before the due date for providing forms to individuals.
  • Details on how to file corrected forms – The draft instructions include details on filing corrected paper returns. Information on electronic filing corrections can be found on IRS Publication 5125.
  • Hand delivery – Both sets of reporting may be hand delivered to individuals.
  • Reporting supplemental coverage – The definition of a “plan sponsor” has been clarified for the purpose of reporting supplemental coverage by the same reporting entity as the health plan sponsor.
  • Reporting coverage offered under multiemployer plans – Simplified reporting now available for reporting offers of coverage for employers with multiemployer arrangements that qualify for relief.
  • Reporting on COBRA participants – Clarifications on how to report COBRA participants.

Instructions and Forms (10/13/15 Final Forms)

Link to Form/Instructions 1094-B

Link to Form/Instructions 1094-C

Link to Form/Instructions 1095-B

Link to Form/Instructions 1095-C

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Fact Sheet: ACA Individual and Employer Mandate Reporting Requirements

CignaThe fact sheet is provided by our partner Cigna and contains the following valuable information:

  • Reporting Basics
  • Large Employer Reporting – Employer Mandate
    • Data to Report
    • Reporting Penalties
  • Minimum Essential Coverage (MEC) Reporting – Individual Mandate
    • Data to Report
    • Reporting Penalties

We encourage you and your HR team to download the Cigna ACA Fact Sheet below:

ACA Reporting Reqs Fact Sheet (Employer/Individual Mandate)




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