Legal Update

Nov 10, 2015

Issue 95: Health Care Reform Reporting Is Coming: Is Your Company Prepared?

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This is the ninety-fifth issue in our series of alerts for employers on selected topics in health care reform. (Click here to access our general summary of health care reform and other issues in this series). This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of certain aspects of health care reform and how it will impact your employer-sponsored plans.
 
For months, large employers and health coverage issuers have been working to understand—and prepare for—their healthcare reporting duties under the Affordable Care Act (ACA).  As we previously reported in Issue 92 (link), in February the IRS released final instructions and Forms 1094-B, 1095-B, 1094-C, and 1095-C for optional ACA reporting on coverage offered in 2014, but even that guidance left many important questions unanswered, effectively stymying reporters’ preparation efforts. Finally, just months before the reporting due dates, the IRS released final instructions and forms for mandatory ACA reporting on coverage offered in 2015.  
 
This client alert presents a high-level, non-exhaustive checklist of action items for employers preparing to report, and briefly discusses notable changes in the final instructions for issuer reporting.