The IRS has released draft forms that insurers and sponsors of self-insured plans can use to demonstrate compliance with the Affordable Care Act (ACA) individual mandate during their annual federal tax filing. The forms may be used beginning in early 2016 to report on the individuals who had coverage during the 2015 calendar year.
The forms will also be used by employers with insured and self-insured plans who are subject to the ACA’s employer mandate to demonstrate compliance. This filing will also be made on the basis of the calendar year, regardless of the fiscal year on which the employer administers its health plan(s)—the first is due in early 2016 and will also be based on the 2015 calendar year.
Non-calendar year health plan sponsors that may defer compliance with the employer mandate until the first day of their plan’s 2015-16 fiscal year still need to file a report with the IRS for the entire 2015 calendar year. Our experts in the Lockton Health Reform Advisory Practice have posted a summary of the final regulations governing these reporting obligations, in the Spring 2014 Compliance News eBook, page 50 (click to download).
The forms are available here in a separate downloadable White Paper (click to download) by Lockton Health Advisory as the original documents do not come with instructions. The Lockton Health Advisory Practice noted that the fact the draft forms do not contain instructions, but expects the IRS to make draft guidance available in September. They’re worth reviewing now because they indicate key data points that are important to the IRS, they said.
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