Upcoming IRC 6055 and 6056 Reporting Deadlines
Employers that were applicable large employers (ALEs) in 2021 and sponsored group health plans (whether insured or self-insured) must comply with IRC Section 6056 reporting in early 2022. Specifically, ALEs must complete and distribute a Form 1095-C to full-time employees by March 2, 2022 (changed from January 31, 2022). The form should detail whether the employee was offered minimum value affordable coverage during 2021. The forms may be mailed, electronically delivered or delivered by hand (although proof of delivery in some manner is recommended).
If an employer sponsored a self-insured plan during 2021, it must comply with Section 6055 reporting in 2022. Self-insured employers with 50 or more FTEs must complete Section III of Form 1095-C detailing which months the employee (and any applicable spouse and dependents) had coverage under the employer’s plan. If the self-insured employer has fewer than 50 FTEs, it must complete and distribute a Form 1095-B with such information. Again, the forms must be delivered to employees by March 2, 2022.
Employers must also file the forms with the IRS by February 28, 2022, if filing by paper, and March 31, 2022, if filing electronically. Those that are filing 250 or more forms are required to file electronically. Lastly, the employer is required to file the transmittal Form 1094-C (if filing Forms 1095-C) or Form 1094-B (if filing Forms 1095-B).
As a reminder, the IRS has provided penalty relief for employers that will allow them to forego distributing Form 1095-B to individuals. This comes after the IRS accepted comments on the necessity of Forms 1095-B now that the individual mandate penalty has been zeroed out. If employers post a notice on their website that the document is available upon request and fulfill any such request within 30 days, then they will not have to distribute Forms 1095-B to covered individuals. But keep in mind that there is no such penalty relief for Form 1095-C.
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