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Beginning in 2015, employers are required to provide information to their employees and to the IRS about their employer-sponsored health coverage, but there’s a lot of confusion about which employers are subject to the requirement and what tax forms they’re required to file. Here’s a quick overview.

Two Requirements

There are actually two employer reporting requirements, and each requires two tax forms.

Section 6055 of the tax code requires providers of minimum essential coverage, which includes insurance companies and self-insured plans, to file an informational return with the IRS and provide notices to each covered member about the health coverage provided.

Section 6056 of the tax code requires applicable large employers (ALEs) to file an informational return with the IRS and provide notices to each employee who was full-time for one or more months during the year.

What forms are required?

The forms that are required depend on whether you are subject to section 6055, 6056, both, or neither.

  • Generally, self-insured companies subject to 6055 file form 1094-B with the IRS and issue form 1095-B to their employees.
  • Applicable large employers subject to 6056 file form 1094-C with the IRS and issue form 1095-C to their employees.
  • Companies that are subject to both requirements don’t have to do all four forms. Instead, they would file form 1094-C with the IRS and complete an additional section on form 1095-C before sending it to their employees.
  • Companies with fewer than 50 employees that are fully-insured or that do not provide health coverage have no reporting requirements.

When are the forms due?

The employee forms (1095-B or 1095-C) must be sent to employees by the end of January.

The employer forms (1094-B or 1095-B) must be sent to the IRS by the end of February, or, if filing electronically, by the end of March. Employers attach the employee forms to the employer transmittal when submitting to the IRS, and companies with 250 or more employee forms must file electronically.

Employer Requirements Webinar

Want more info? Check out our one-hour webinar on the new employer reporting requirements.