Here’s a brief summary of the clarifications released in 2014 regarding Sections 6056 and 6055 from the agencies. Collectively, I will refer to the Department of Labor, Treasury and Health and Human Services as the ‘Agencies’.
Section 6056 Reporting
- Requires applicable large employer members to file an IRS form (similar to and in addition to a W-3) which identifies each of the employees who were full time at least one month of the calendar year and what, if any, coverage was offered. A form is also to be furnished to those full-time employees (similar to and in addition to a W-2). As of February 11, 2015 (1094-C and 1095-C) were finalized by the IRS.
- Section 6055 Reporting
- Requires minimum essential coverage (MEC) providers to file an IRS form identifying each individual enrolled at least one day during that year. This applies to any employer who offers a self-insured plan into any individuals covered under the plan. The form must also be provided to covered individuals. Fully insured carriers will satisfy this obligation with respect to individuals covered under the policy. Employers sponsoring a self-insured plan are obligated to satisfy the requirement with respect to all individuals enrolled. As of February 11, 2015 (1094-C and 1095-C) were finalized by the IRS.
Source: Employers Council on Flexible Compensation: John Hickman, Esq., Ashley Gillihan, Esq., and Merdith Gage, Esq., Alston & Bird, LLP