Links to IRS Forms 1094 and 1095 plus instructions!

Posted on Feb 3, 2016 in Health Care Reform

The forms for 1094 and 1095 healthcare reporting are available online from the Internal Revenue Service website.

As a refresher:

  1. Form 1094-C is used by employers to give an overview of their plan and cost, and to prove they offered minimum essential coverage to their employees.
  2. Form 1095-C is used by employees and employers to show if they had minimum essential health coverage during the year.

The Internal Revenue Service has the forms available online, along with instructions to help employers complete the forms.

Form 1094-Chttps://www.irs.gov/pub/irs-pdf/f1094c.pdf

Form 1095-Chttps://www.irs.gov/pub/irs-pdf/f1095c.pdf

Instructions for completing Forms 1094-C and 1095-Chttps://www.irs.gov/pub/irs-pdf/i109495c.pdf

Keep in mind that the links above are for reports due for plan year 2015. Each year the IRS may adjust these forms and update them, so be sure you are using the form for the correct tax year.

For questions on how to find plan information or plan reports to complete these documents, check with your Benefit Advisor or your Third Party Administrator.

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Employer Health Plan Reporting 6055 & 6056, 1095

Posted on Jan 28, 2016 in Health Care Reform

Employer reporting requirements and information on Forms 1095 and 1094

6055 Overview – Minimum Essential Coverage Reporting

Section 6055 requires health insurers and sponsors of self-insured plans to report on Minimum Essential Coverage (MEC) to the IRS annually. The reporting to both individuals and the IRS for 2015 is due in early 2016. It also requires insurers and self-insured plans to report to their MEC recipients, so the individuals can report that coverage when filing their federal taxes.

The 6055 reporting requirement has two goals:

  1. It helps individuals verify that they have MEC for purposes of satisfying the Individual Shared Responsibility requirement and
  2. It enables the IRS to crosscheck that information with insurers or self-insured plans.

Entities subject to 6055 reporting are health insurance issuers, sponsors of self-insured plans, government sponsored programs, such as Medicaid, and providers of other arrangements designated as MEC, such as high-risk pools.

The final rule states that self-insured employers are responsible for reporting this information to the IRS. Health insurers will provide reporting to the IRS for fully insured groups. If a self-funded employer needs information on covered members and their coverage dates for a calendar year to meet their part of their reporting obligation, a report of covered individuals may be available from the Third Party Administrator.

Information required to be reported to the IRS by health insurers and sponsors of self-insured plans who provide minimum essential coverage:

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The “Cadillac Tax” – IRS issues Notice on 40% Excise Tax

Posted on Aug 3, 2015 in Health Care Reform, Industry & Legislative News

On July 30, the Department of the Treasury and the Internal Revenue Service (IRS) issued a second notice regarding the 40% Excise Tax a.k.a. the Cadillac Tax. The notice provides information on possible approaches that are being considered for administering the Cadillac Tax and continues the process of gathering input that will be used to develop regulations.

This is a follow-up to the notice issued on February 23, 2015, and comments may be submitted until October 1, 2015.

The notice addresses several issues, including:

  • Who pays the tax
  • How the tax will be determined
  • How the tax will be paid

Who Pays the Tax

Each “coverage provider” must pay the tax on its share of the excess benefit. A coverage provider is:

  • The health insurer for insured coverage.
  • The employer for accounts such as Health Savings Accounts (HSAs) to which the employer contributes.
  • The plan benefits administrator – the agencies are seeking comments on whether this should be the third-party administrator or the entity that has ultimate responsibility for plan administration, typically the employer.

How the Tax will be Determined

The notice seeks comments on how to calculate and administer the tax. The following are some of the proposed approaches:

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Supreme Court rules health premium subsidies legal in all States

Posted on Jun 25, 2015 in Health Care Reform, Industry & Legislative News

The Supreme Court released their ruling on King v. Burwell today. The vote was 6-3 in favor of upholding health premium subsidies in all States, including States that have a Health Plan Exchange run by the Federal Government.

Now that the decision is made, we will most likely see action in Congress to clean up parts of the Affordable Care Act.

Here is a link to the Supreme Court’s Opinion: http://www.supremecourt.gov/opinions/14pdf/14-114_qol1.pdf

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New EEOC Ruling affects Workplace Wellness Programs

Posted on Jun 10, 2015 in Health Care Reform, Industry & Legislative News

The proposed rules on use of financial incentives within workplace wellness programs were published by the Equal Employment Opportunity Commission (EEOC) on April 16, 2015.   These rules align the wellness provisions of the Affordable Care Act (ACA) and the Health Insurance Portability and Accountability Act (HIPAA) with the nondiscrimination rules in the Americans with Disabilities Act (ADA).

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2016 Small Group Redefinition Impacts Rating, Coverage, and Underwriting

Posted on Jun 10, 2015 in Health Care Reform, Industry & Legislative News

As employer groups with 51-100 employees renew or purchase health insurance coverage in 2016, they must abide by the rules and regulations governing the small group market, including those related to benefit coverage and essential health benefits; actuarial value, and premium rating restrictions, such as adjusted community rating and no medical underwriting.

The small group rules apply to fully insured plans, including those purchased in the Small Business Health Options Program (SHOP) marketplace.

In some markets, the state and insurance carriers may give employers the option to keep their plan for a while longer by:

  • Changing their plan year to maximize the time the employer can keep their plan in 2016.
  • Taking advantage of transitional relief, which allows employers in some states to keep their current plans through Sept. 30, 2017.

Employers that self-insure (self-funded) are not subject to these requirements.

Options and requirements vary by state, issuer and segment. For more information, please contact us for a consultation at 832-482-2494 or via email through the “contact us” page on our website.

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