Some Welcome Relief and Clarification on Affordable Care Act for Employers

January 22, 2016

As the federal agencies continue to issue more guidance on the application of various provisions of the Affordable Care Act (the “ACA”) to employer-sponsored health coverage, there are some recent developments that we want to highlight that should be of interest to employers who sponsor group health plans.

Extension of Deadlines for Section 6055 and 6056 Reporting

Through Notice 2016-4, the Internal Revenue Service (the “IRS”) extended the deadlines for the 2015 information reporting requirements (for both furnishing to individuals and filing with the IRS) under Sections 6055 and 6056 of the Internal Revenue Code (the “Code”).

Section 6055 of the Code requires health insurance carriers, self-insuring employers and other providers of “minimum essential coverage” to file with the IRS, and furnish to covered individuals, annual information returns and statements regarding such coverage. Section 6056 of the Code requires “applicable large employers” (generally those with 50 or more full-time employees, including full-time equivalents, in the previous year) to file with the IRS, and furnish to covered employees, annual information returns and statements relating to health coverage that the employer has offered (or not) to its full-time employees.

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