IRS Releases Draft Forms and Instructions for Reporting of Health Insurance Coverage The IRS has issued draft forms and instructions for 2014 for forms that will be used by employers, health insurers, and Health Insurance Marketplaces (Exchanges) to report health insurance coverage under the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148). The IRS reported that it is aiming to release final forms and instructions as soon as possible. CCH Take Away. The ACA’s employer shared responsibility requirement (“employer mandate") was scheduled to apply in 2014, but the IRS, in Notice 2013-45, announced it would postpone the employer mandate until 2015, to give employers more time to prepare for the related requirements. Some mid-size employers are exempt until 2016. The ACA’s individual shared responsibility requirement (“individual mandate") and the Code Sec. 36B premium assistance tax credit apply for 2014. Background Under Code Sec. 6055, health insurance providers that furnish minimum essential coverage (MEC) to individuals and families must file annual returns. Code Sec. 6055 requires reporting by health insurance issuers, self-insurers, government agencies that administer government insurance programs, and other entities. Under Code Sec. 6056, applicable large employers (generally businesses with 50 or more full-time employees, including full-time equivalent employees) must report health insurance coverage provided to their full-time employees. Reporting originally had been required for 2014, to implement the employer mandate that requires employers to furnish MEC to their employees. However, the IRS postponed reporting under Code Secs. 6055 and 6056 until 2015. Subsequently, the IRS further postponed the employer mandate and related reporting until 2016 for businesses with at least 50 but fewer than 100 full-time employees, including full-time equivalent employees. Forms The IRS is furnishing the appropriate forms and instructions for 2014 so that employers and insurance providers can prepare their systems for 2015 reporting in 2016 and can practice, for 2014, fulfilling their upcoming reporting obligations. The required forms include: Form 1095-A, for Marketplaces; Form 1094-B, Transmittal of Health Coverage Information Returns, and Form 1095-B, Health Coverage; and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. Form 1095-B indicates who provided health insurance coverage to a taxpayer, the type of coverage, who was covered, and the period of coverage. Form 1095-C provides similar information for coverage provided by an employer to a full-time employee. A separate form must be furnished for each employee. Form 1095-C is a combined form with separate sections for reporting under Code Secs. 6055 and 6056, for employers who self-insure their provision of health benefits.