CMS has posted an updated Marketplace Employer Appeal Request Form dated July 2016. The updated form includes formatting changes to the contact information sections and is available here.
The IRS recently released draft instructions for Forms 1094/1095 that correspond with the draft Forms 1094/1095 the IRS released in July (please see our prior blog post on the draft forms?áhere). Highlights of the changes and clarifications in the draft instructions for Forms 1094/1095 include: Certain transition relief available in 2015 remains available for non-calendar year plans for the portion of the 2015 plan year that ends in 2016; Certain coding used in Forms 1094-C/1095-C has been reserved for 2016; and Retirees who separated from employment should be reported the same as COBRA participants who separated from employment. Filing Dates and Extensions: To the IRS. The 2016 Form(s) 1094-C and accompanying Forms 1095-C must be filed electronically with the IRS by March 31, 2017 (February 28, 2017 if paper filing is used). An automatic 30-day extension is available if filed no later than the due date. Another 30-day extension may… Continue Reading
IRS Issues Proposed Regulations Addressing Certain Minimum Essential Coverage Reporting Issues Under Code Section 6055
The IRS issued proposed regulations on August 2, 2016, clarifying certain minimum essential coverage (?Ç£MEC?Ç¥) reporting issues related to IRS Forms 1095-B and 1095-C, Part III. Form 1095-B is used to report MEC by insurance carriers for fully-insured MEC and by small employers with self-insured MEC who are not otherwise subject to the employer shared responsibility provisions of the Affordable Care Act. Form 1095-C, Part III is used by large employers with self-insured MEC. A change that is of significant interest to reporting entities is the revised safe harbor for soliciting TINs (e.g., SSNs) from covered participants. The revised safe harbor still requires up to three attempts to obtain a covered participant?ÇÖs TIN pursuant to specific procedures set out in the proposed regulations. The covered participant?ÇÖs date of birth may continue to be used as a substitute for solicited TINs missing when reporting is due. A reporting entity does not… Continue Reading