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IRS Releases Draft Instructions for ACA Reporting Forms

The Internal Revenue Service (the ?Ç£IRS?Ç¥) released draft instructions for the forms that employers will use to report certain information required by the Affordable Care Act (the ?Ç£ACA?Ç¥).?á Draft instructions have been released for Forms 1095-C (Employer-Provided Health Insurance Offer and Coverage), 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns), 1095-B (Health Coverage), and 1094-B (Transmittal of Health Coverage Information Returns).?á Large employers (i.e., those with at least 50 full-time employees or equivalents) will use Forms 1095-C and 1094-C, while small employers offering ?Ç£minimum essential coverage?Ç¥ to their employees will use Forms 1095-B and 1094-B.?á Draft versions of these forms were released by the IRS in July. ?áAlthough these ACA reporting forms will be required for the first time in early 2016 (to report information related to the 2015 calendar year), the instructions provide that employers may voluntarily report information pertaining to the 2014 calendar year in accordance with the draft forms and instructions.

A copy of the draft instructions for Forms 1095-C and 1094-C is available here.?á

A copy of the draft instructions for Forms 1095-B and 1094-B is available here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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September 2014