The Patient Protection and Affordable Care Act (PPACA) enacted IRS Sections 6055 and 6056. Section 6055 requires all self-insured employers to file a yearly report of the coverage provided to their subscribers. Section 6056 requires every applicable large employer* (ALE) to file a yearly report of the coverage offerings it made to its full-time employees. These reports are designed to monitor compliance with the PPACA individual and employer mandates.
(*An employer with 50 or more full-time equivalent employees is considered an ALE.)
The compliance reporting is accomplished via IRS Forms 1094 and 1095. Form 1095 is delivered to each subscriber or employee, referred to as the Responsible Individual.
This form is also filed with the IRS for each individual. Form 1094 is a transmittal form that is filed with the IRS along with the 1095s. This is an analogous process to W3/W2 filing every year.
There are two versions of these forms, the B version and the C version. The B version is designed for Insurers to report the coverage they provided (6055 reporting). The C version is designed for ALEs to report on the coverage they offered to their full-time employees (Section 6056 reporting).
Self-insured employers who are ALEs must comply with both Section 6055 and 6056. They may use the C version exclusively rather than file both forms. There is a section of the C version where enrollment data may be reported and there is a check box to indicate the employer is self-insured.
1095 forms must be mailed to the Responsible Individuals by 2/1/2016. Paper filing to the IRS must be completed by 2/29/2016 or, if filing electronically, by 3/31/2016. Anyone submitting 250 or more 1095 forms must file electronically.
Please send questions to Mark.Pfohl@nctreasurer.com.