The Internal Revenue Service has issued draft copies of the health care coverage forms employers will have to provide to full-time employees and to the IRS starting in 2016.
Among other things, form information will include the names of covered employees and dependents; their Social Security numbers or, if not available, their dates of birth; whether they were covered in the employer’s health care plans for the full year or, if not, the months that they were covered; and the employee share of the monthly premiums for individual coverage in the lowest-cost plan providing minimum coverage.
The forms, providing 2015 coverage information, will have to be distributed to employees by Jan. 31, 2016, and to the IRS by the end of March 2016.
While the IRS earlier exempted — for 2015 only — employers with between 50 and 99 employees from a Patient Protection and Affordable Care Act provision that requires employers to offer coverage or pay a stiff fine, that one-year coverage exemption will not excuse those employers from filing the coverage form.
Those smaller employers “still will face this filing requirement,” said Amy Bergner a managing director with PricewaterhouseCoopers L.L.P. in Washington. Information on the documents will be used by regulators to determine if employers are offering coverage, whether employees have enrolled in plans and whether individuals are eligible for premium subsidies in public insurance exchanges.
“This will be a very significant health care reform reporting requirement,” said Rich Stover, a principal with Buck Consultants at Xerox in Secaucus, New Jersey. “It will require a lot of work.”
Employers can impose a one-month orientation period before a 90-day waiting period starts to either offer qualifying employees group health insurance or face a penalty, according to the latest federal guidance on complying with the health care reform law.