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Information Reporting by Applicable Large Employers

The Affordable Care Act added significant new reporting requirements to the Internal Revenue Code (IRC). IRC section 6056 requires each Applicable Large Employer (ALE) subject to the Employer Mandate to report on their employer-sponsored coverage and to whom it is offered. This reporting is designed to assist the Internal Revenue Service (IRS) with enforcing the Employer Mandate and administering the premium tax credit.

There are two components to the reporting requirement:

  • Reporting to the IRS on each full-time employee, regardless of whether they were offered coverage, and
  • Furnishing of a statement to each employee identified in the IRS reporting.

All ALEs are responsible for reporting under section 6056. The regulations provide for a general reporting method, as well as simplified alternative reporting methods. Under the general reporting method, information provided to the IRS includes, but is not limited to, the following:

  • The total number of ACA defined full-time employees by calendar month.
  • Certification of whether the ALE offered its full-time employees (and their dependents) MEC by calendar month.
  • Name, address, tax identification number (SSN/TIN) of each full-time employee and the months during the calendar year for which MEC was available.
  • For each full-time employee, the employee’s required contribution for the lowest cost self-only coverage that provides minimum value (MV) by calendar month.
  • For each full-time employee, whether an affordability safe harbor was used.

In general, the simplified alternative reporting methods limit the amount of information ALEs must report; however, in order to use one of these methods, the ALE must meet certain requirements.

Additional Information

IRS Extends Due Date for Furnishing IRS Form 1095-C to Employees
     The IRS issued Notice 2016-70 on November 18, 2016 extending the deadline for furnishing Form 1095-C to employees and extending good-faith transition relief to the 2016 reporting year.

Non-Calendar Year Plans IRC §4980H Transition Relief & IRC §6056 Reporting
     This Briefing provides examples of how the Employer Mandate transition relief for non-calendar year plans relates to the reporting under IRC section 6056.

Health Care Reform: IRC §6056 Information Reporting on Employer-Sponsored Coverage
     This Briefing outlines the reporting requirements under Internal Revenue Code section 6056, including the information to be reported and the simplified reporting methods that are available.

IRS: Summary of IRC Section 6056 Reporting Requirements

IRS: Questions and Answers on Reporting of Offers of Health Insurance Coverage by Employers (Section 6056)

IRS: Questions and Answers about Information Reporting by Employers on Form 1094-C and Form 1095-C