The ACA's new IRS reporting requirements for employers continue to be the hottest new compliance topic of 2015. To confirm, these requirements apply to employers that had 50 or more full-time employees, including full-time equivalents, during 2014. Employers subject to the requirements will have to provide Form 1095-C by 2/1/16 to all employees that were full-time during 2015, and provide Form 1094-C to the IRS, along with copies of all Forms 1095-C, by 2/29/16 (3/31/16 if electronically submitted).
On September 18, the IRS issued the final 2015 versions of Form 1094-C and Form 1095-C, along with applicable instructions. The IRS had previously issued a fact sheet, two sets of FAQs on topic (here and here), as well as a trifold handout to assist employers.
The final versions of the forms and instructions largely confirm the details of the draft versions. The instructions do clarify several important issues, including that employers are not required to report HRA coverage as self-funded coverage in Part III of the Form 1095-C as long as the HRA is provided in addition to other minimum essential coverage (including a medical insurance plan). This was our previous understanding and communication, but the issue had been confused by informal IRS comments prior to the formal release of the instructions. This relieves a potential reporting obligation for HRA sponsors, which now can focus on reporting of the primary medical insurance as planned.