ACA Reporting: Section 6055 and 6056
Due to the delay of the 2014 Section 6055 and 6056 reporting to 2015, the penalties associated with the Employer Mandate were also delayed. The clarification around these reporting requirements have been made available and provided as final regulations.
Section 6055 and 6056 reporting is required of large employers. Large employers are defined by the IRS as having over 50 full-time employees, including FTEs (full time equivalents). Employers that have fewer than 50 full-time employees, including FTEs, are considered small employers and are exempt from the employer shared responsibility.
The funding arrangement of the plan will dictate who’s responsible to complete which sections. Employers offering a self-insured plan will be required to complete both Section 6055 and 6056. Employers offering a fully insured plan will be required to complete Section 6056; the carrier will complete section 6055.
Section 6055 reporting will require information about the entity providing coverage, including contact information. The report will also be required to list which individuals are enrolled, demographic detail on each member (including the Tax ID number for each employee and dependent) and the months for which they were covered.
Section 6056 reporting will require the same level of information as the Section 6055 reporting with the exception of the Tax ID number of each dependent; employee Tax ID will still be required. In addition, detail on the number of full-time employees will be required. For each full-time employee, the report will list coverage offered to the employee, by month, and the lowest employee cost of self-only coverage.
The report format has been provided in the final regulations and the information will be submitted by employers on a single, consolidated form. The form is separated into two sections; the top will be information required for the 6056 reporting and the bottom will be the required 6055 information.
Employers with 250 or more employees will be required to file Section 6055 and 6056 reports electronically. Employers with less than 250 employees, although encouraged to file electronically, will be allowed to submit manually. The deadline for report submission if filed electronically is March 31 and if filed manually is February 28.
In addition to reports required to be submitted to the IRS, employers also have a responsibility to provide an individual statement to employees. Statements to individuals are required to be provided annually by January 31.
For more information on reporting requirements, view our Assurance University: Reporting Requirements webinar recording.
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