IRS Issues Employer Shared Responsibility Reporting Q&A

September 26, 2014

This summer, the IRS issued draft forms and instructions for employers subject to the Employer Shared Responsibility mandate (§4980H).  Recently, the IRS issued corresponding Questions and Answers on the employer reporting requirements (§6056).

Reporting is voluntary for the 2014 calendar year.  For the 2015 and subsequent calendar years, employers will report offers of coverage to each full-time employee by month, with a summary to the IRS. For the 2015 calendar year, Forms 1095-C must be distributed to employees by January 31, 2016 and the transmittal Form 1094-C with copies of the Forms 1095-C must be submitted to the IRS by February 28, 2016 (or March 30, 2016 if filed electronically).  Note that reporting is by calendar year, even if you maintain a non-calendar year medical plan.