The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue (IRS) Code Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) or provide to their employees. Reporting is first required in 2016, related to coverage offered or provided in 2015.

On June 16, 2015, the Internal Revenue Service released 2015 draft versions of the forms that employers will use to report under Sections 6055 and 6056. Instructions for the 2015 forms have not yet been released.

• Form 1094-B and Form 1095-B will be used by entities reporting under Section 6055, including sponsors of self-insured group health plans that are not reporting as applicable large employers (ALEs).
• Form 1094-C and Form 1095-C will be used by ALEs that are reporting under Section 6056, as well as for combined reporting by ALEs who sponsor self-insured plans that are required to report under both Sections 6055 and 6056.

Except for a few minor changes the 2015 draft forms are largely unchanged from the 2014 versions.

Under both Sections 6055 and 6056, each reporting entity will be required to file all of the following with the IRS:

• A separate statement (Form 1095-B or Form 1095-C) for each individual who is provided minimum essential coverage (for providers reporting under Section 6055), or for each full-time employee (for ALEs reporting under Section 6056); and
• A single transmittal form (Form 1094-B or Form 1094-C) for all of the returns filed for a given calendar year.

The first returns required to be filed are for the 2015 calendar year and are due no later than Feb. 29, 2016, (Feb. 28, 2016, being a Sunday), or March 31, 2016, if filed electronically. Any reporting entity that is required to file at least 250 returns under either Section 6055 or Section 6056 must file electronically.

In addition, each reporting entity will be required to furnish statements annually to individuals who are offered or provided minimum essential coverage (for ALEs, this includes only full-time employees) on or before Jan. 31 of the year immediately following the calendar year to which the statements relate. The 2015 statements must be furnished no later than Feb. 1, 2016 (Jan. 31, 2016, being a Sunday). Extensions may be available in certain circumstances.

These 2015 forms and instructions are draft versions only and should not be filed with the IRS or relied upon for filing. The IRS may make changes prior to releasing final 2015 versions.

Contact your NEEBCo representative with questions regarding your requirement to complete these forms.