On March 5, 2014, the Internal Revenue Service released the two final rules on ACA health coverage reporting requirements.  The new rules are intended toprovide the IRS with information necessary to administer other ACA mandates suchas the large employer shared responsibility penalty and Individual Mandates.

• Section 6055 - requires health insurance issuers, self-insured health plan sponsors, government agencies that administer government-sponsored health insurance programs or any entity that provides Minimum Essential Coverage (MEC) to report coverage information to the IRS.

 IRS Notice 2013-45 provides the finalize proposed rules that were issued on September 5, 2013

• If you are fully-insured your insurance carrier should handle the Section 6055 reporting for you. Self-insured groups are responsible for the Section 6055 reporting.

• Section 6056 - applies to applicable large employers (ALEs) with an average of at least 50 full-time employees.  Applicable large employers subject to the ACA's employer shared responsibility provisions, must file a return with the IRS that reports the terms and conditions of the health coverage provided to the employer's full-time employees.

• More guidance will be forthcoming as 2015 draws near.  Payroll vendors have discussed helping their clients with the data needed for the Section 6056 reporting. We would advise you to check with your payroll vendor to see if that is a service they offer.

The final regulations for Code sections 6055 & 6056, will apply for calendar years beginning after December 31, 2014. The reporting becomes effective in 2015, with the first tax returns due in 2016.