IRS Issues FAQs relating to PPACA Informational Reporting under Sections 6055 and 6056
under Sections 6055 and 6056
On Sept. 22, 2014, the IRS released two sets of FAQs discussing the informational reporting requirements under Internal Revenue Code Sections 6055 and 6056. Section 6055 requires employers that sponsor self-insured plans to report specific information to the IRS and to plan participants which will assist the IRS in administering and enforcing the individual mandate. Section 6056 requires applicable large employers who are subject to the employer mandate to report certain information to the IRS and to plan participants to help administer and enforce the employer mandate and eligibility for premium tax credits. Reporting under both sections is required in early 2016 for calendar year 2015.
The Section 6055 FAQs address the basics of employer reporting, including which entities are required to report, what information must be reported and how and when reporting entities must report required information. The Section 6056 FAQs cover the same topics and also address questions related to the methods of reporting.
Importantly, the FAQs clarify that due to the leap year in 2016, for the first year (reporting on 2015 calendar-year compliance), reports are due Feb. 29, 2016, rather than March 1, 2016 as previously reported. The reports are due March 31, 2016, if filing electronically. Electronic filing is required of employers filing 250 or more Section 6056 returns (employee statements). These dates apply regardless of the plan year of the employer-sponsored coverage. For example, reporting is due on those dates for 2015 compliance, even if the plan year runs from May 1 through April 30. In addition, like the Form W-2, employers must distribute employee statements by Jan. 31 of the following year (i.e., Feb. 1, 2016, for 2015 compliance because Jan. 31, 2016 is a Sunday) although employers may apply for a 30-day limited extension.