The Internal Revenue Service on Thursday released drafts of
the forms employers will use to report on health coverage they offer to their
employees, unveiling a glimpse of the administrative onus in store for benefit
advisers and their employer clients working to comply with the Affordable Care
Act.
Despite continuing calls to further delay the mandate and
confusion about employer shared responsibility requirements following
conflicting court rulings just this week on ACA subsidies offered on the
federal exchange, the IRS posted to its website draft forms for employers and
individuals to use when reporting their health coverage starting in 2015.
The draft forms have been provided to help stakeholders,
including employers, tax professionals and software providers, prepare for the
new reporting provisions and to invite comments from them, the agency says.
While the forms provide benefit advisers and employers a
much needed preview of forthcoming reporting requirements, there remains the
possibility that the finalized versions of the forms will look different.
“While more information is better, the caveat is that the
forms are subject to change,” says Les McPhearson, CEO of United Benefit
Advisers. “The question for employers and advisers remains — ‘How invested do I
get in this?’”
He adds, however, that the forms could be helpful “in
providing a glimpse of where the IRS, Department of Health and Human Services
and Centers for Medicare and Medicaid Services are heading in terms of
accounting, administration, and reporting requirements.”
The IRS says it anticipates draft instructions relating to
the forms will be posted to its website in August and both the forms and
instructions will be finalized later this year.
The agency says it has simplified the paperwork and reduced
the number of forms and categories some companies will be required to complete.
For example, the forms allow some employers to check a box that says an
employee is covered on the employer-sponsored group plan for 12 months, rather
than reporting coverage on a monthly basis.
Special Rule: As part of an effort to streamline the reporting process, applicable large employers that sponsor self-funded health plans are to report the information required of them for both the individual and employer mandates on a single combined form using Form 1095-C. Substitute forms will be permitted if they include all of the content required by the prescribed forms and meet other IRS requirements.
The forms aim to
fulfill the reporting requirements as follows:
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Special Rule: As part of an effort to streamline the reporting process, applicable large employers that sponsor self-funded health plans are to report the information required of them for both the individual and employer mandates on a single combined form using Form 1095-C. Substitute forms will be permitted if they include all of the content required by the prescribed forms and meet other IRS requirements.
Early releases of draft forms and instructions are at IRS.gov/draftforms. Please note that drafts may remain on IRS.gov even after the
final release is posted at IRS.gov/downloadforms, and thus may not be removed
until there is a new draft for the subsequent revision. All information about
all revisions of all forms, instructions, and publications is at IRS.gov/formspubs
Source: Employee Benefits Adviser
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