In a recent article produced by Employee Benefit News, they outline the 2016 requirements employers are subject to meet under Internal Revenue Code Sections 6055 and 6056. The requirements apply to employers that sponsor self-insured plans that provide minimum essential coverage regardless of size and applicable large employers (ALEs).

ALEs

Defined by the IRS, an ALE is short for Applicable Large Employer. An ALE is determined each calendar year based on whether the employer has more than 50 full-time employees, including full time equivalent employees, on average during the prior year.

If an employer qualifies as an ALE they are then subject to the employer shared responsibility provisions and the employer information reporting provisions.

Code Section 6055 Requirements

stethoscope and gavelUnder Code Section 6055, employers who self-fund their health plan are required to report the following information related to their provider coverage:

  • The name, address and employer identification number of the provider;
  • The name, address and tax identification number (TIN) (or date of birth if a TIN is not available) of the individual who enrolls one or more individuals in the plan (typically the employee) (referred to herein as the responsible individual);
  • The name and TIN (or date of birth if TIN is not available) of each individual covered under the plan, and the months for which the individual was enrolled; and
  • Any other information specified in forms, instructions or published guidance.

Code Section 6056 Requirements

Code Section 6056 requires reporting about the health care coverage of the self-insured plan that self-funded employers offer to their full-time employees. Required information includes:

  • The ALE’s name, address and EIN;
  • The name and telephone number of the ALE’s contact person;
  • The calendar year for which the information is reported;
  • A certification as to whether the ALE offered to its full-time employees (and their dependents) the opportunity to enroll in minimum essential coverage under the plan, by calendar month;
  • The months during the calendar year for which minimum essential coverage under the plan was available;
  • Each full-time employee’s share of the lowest cost monthly premium (self-only) for coverage providing minimum value offered to the employee under the plan, by calendar month;
  • The number of full-time employees for each month during the calendar year;
  • The name, address and TIN of each full-time employee during the calendar year, and the months, if any, during which the employee was covered under the plan; and
  • Any other information specified in forms, instructions or published guidance.

Reporting Deadlines

Health coverage providers must file the information return and transmittal form with the IRS on or before Feb. 28, 2016 for the previous calendar year in which it provided minimum essential coverage to individuals.

  • Statements to employees must be distributed by Feb. 1, 2016. Regulations under section 6081 address extensions of time to file information returns.
  • Returns to the IRS must be filed by Feb. 28, 2016 or March 31, 2016 if filed electronically. (If more than 250 files, information must be filed electronically.)

View the full article here.

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