The IRS released final regulations to implement simplified reporting requirements of employers to report health care coverage information under Secs. 6055 and 6056 starting in 2015 (T.D. 9660 and T.D. 9661).
Sec. 6055 requires providers of minimum essential coverage and providers of coverage through an employer’s group health plan to report information that will allow taxpayers to establish and the IRS to verify that the taxpayers were covered by minimum essential coverage and their months of enrollment during a calendar year.
Sec. 6056 requires applicable large employers (generally, employers with 50 or more full-time employees) to report to the IRS information about the coverage that they offer to their full-time employees and requires them to furnish related statements to employees. To reduce the reporting burden for these employers, the final rules provide for combining reporting under both Secs. 6055 and 6056 on one form. Employers that are subject to the employer mandate and are self-insured will complete both halves of the form; those that are not self-insured will complete only the top half.
Also, employers that provide a “qualifying offer” to any of their full-time employees will be allowed a simplified alternative to reporting monthly, employee-specific information on those employees.
The regulations apply to calendar years beginning after Dec. 31, 2014.
In addition, Treasury, along with the departments of Labor and Health and Human Services, issued final regulations (T.D. 9656) implementing the 90-day waiting period limitation applying to group health plans and group health insurers for plan years beginning on or after Jan. 1, 2015.
T.D. 9660 and T.D. 9661; T.D. 9656
By Sally P. Schreiber, J.D., a JofA