Helping your clients understand the new ACA tax implications

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As you may have heard, there are two new reporting requirements—Section 6055 and Section 6056—for your clients to be aware of for 2016. They are the result of changes to the Internal Revenue Code due to the Affordable Care Act.

Section 6055
Code Section 6055 requires health insurance issuers, certain employers, and other entities to furnish the IRS with information relating to covered individuals that have been provided Minimum Essential Coverage (MEC). Required information includes:

  • Name, address, and Social Security number of all covered individuals.
  • Months for which individuals were enrolled in coverage for at least one day.
  • Name, address, and Employer Identification Number of plan sponsor (for fully insured group health coverage).
  • A statement disclosing MEC information must be furnished to plan subscribers.

Section 6056
Code Section 6056 applies to Applicable Large Employers (ALE), who generally employ 50 or more full-time employees and full-time equivalents (employers subject to the employer shared responsibility rules). Required information includes:

  • Name, address, and Social Security number of all covered individuals.
  • Coverage (if any) that was offered to an employee, by month.
  • The employee’s share of the lowest cost monthly premium.

Important Note For Self-Funded Employers
Self-funded employers are subject to both Section 6055 and Section 6056 reporting.

Forms Used

INDIVIDUAL/GROUP TYPE SECTION CODE REQUIRED FORM
Individual (on-exchange*) 6055 N/A (1095-A sent by the exchange*)
Individual (off-exchange*) 6055 1095-B
Small group fully insured
(both SHOP exchange and off-exchange*)
6055 1095-B
Small group self-funded 6055 1095-B
Applicable large employer
(fully insured)
6055
6056
1095-B
1095-C Parts I, II
Applicable large employer
(self-funded)
6055
6056
1095-C All parts

*Washington Healthplanfinder

Also see:
Health insurance and taxes: What’s important?
Your 1095-A Statement

UPDATED: Important Dates to Remember

New Due Dates 
Recently, the IRS issued new guidance delaying when the forms are due under Sections 6055 and 6056 of the Internal Revenue Code for 2015. The due date for providing the 2015 forms 1095-B and 1095-C to individuals have been delayed from Feb. 1, 2016 to March 31, 2016. The due date for filing the forms and the 1094-B and 1094-C transmittal forms with the IRS was delayed from Feb. 29, 2016 to May 31, 2016. There is no timeframe change to form 1095-A.

2015 REPORT PRIOR REPORTING DEADLINE NEW REPORTING DEADLINE
Form 1095-A 2/01/2016 No change
Form 1094-B (Transmittal of Health Coverage Information Returns) 2/29/2016 (Paper Filing)
3/31/2016 (Electronic Filing)
5/31/2016 (Paper Filing)
6/30/2016 (Electronic Filing)
Form 1095-B (Health Coverage) 2/1/2016 3/31/2016
Form 1094-C (Employer-Provided Coverage Transmittal Form) 2/29/2016 (Paper Filing)
3/31/2016 (Electronic Filing)
5/31/2016 (Paper Filing)
6/30/2016 (Electronic Filing)
Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) 2/01/2016 3/31/2016