GDP Blog

6056 What Information Needs To Be Reported

Posted by John Powter

May 10, 2015 8:22:00 AM

Last week we wrote about IRS Code 6055, this week we cover the 6056 IRS Code and what you need to report. If you have any questions or need help filing these forms contact your GDP Advisor at 800-473-8697.Compliance2-843830-edited

The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Section 6056. These new reporting rules require applicable large employers subject to the ACA’s employer shared responsibility rules to report information on the health coverage offered to full-time employees to the Internal Revenue Service (IRS) and covered individuals. Related statements must also be provided to individuals.

Required Forms

The Section 6056 reporting will be accomplished using forms 1094-C and 1095-C. Each ALE is required to file the following forms with the IRS:

  • A single transmittal form (Form 1094-C) for all of the returns filed for a given calendar year
  • A separate employee statement (Form 1095-C) for each full-time employee.

On Feb. 8, 2015, the IRS released final versions of Forms 1094-C and 1095-C (and related instructions). Note that these forms are for use in 2014. Reporting is not required for 2014, but reporting entities may voluntarily file these forms in 2015 for 2014 coverage. Reporting is first required in early 2016 for calendar year 2015. Forms and instructions for 2015 reporting have not yet been released and may contain some changes.

An ALE that maintains a self-insured plan must also report under Code Section 6055 as a provider of minimum essential coverage (MEC). Entities that are reporting under both Sections 6055 and 6056 will file using a combined reporting method, on Form 1094-C and Form 1095-C. The Form 1095-C has separate sections to allow ALEs that sponsor self-insured plans to combine reporting to satisfy both the Section 6055 and 6056 reporting requirements, as applicable, on a single return.

This Legislative Brief outlines the information required to be reported on Forms 1094-C and 1095-C under Code Section 6056. Please contact GDP Advisors LLC (1-800-473-8697) if you need more information on Section 6056 reporting.

Reporting entities

The Section 6056 reporting requirements apply to “applicable large employers” (ALEs) subject to the ACA’s employer shared responsibility rules. An ALE is an employer that employed an average of at least 50 full-time employees, including full-time equivalents (FTEs), on business days during the preceding calendar year. Full-time employees are those employed, on average, at least 30 hours of service per week. Whether an employee qualifies as a full-time employee is determined under either the look-back measurement method or the monthly measurement method, as described in the employer shared responsibility final regulations.

Section 6056 applies to all employers that are ALEs, regardless of whether coverage is offered to full-time employees, and regardless of whether the employer is a tax-exempt or government entity (including federal, state, local and Indian tribal governments). However, only ALEs with full-time employees are subject to the Section 6056 requirements (and only with respect to their full-time employees).

Thus, ALEs without any full-time employees are not subject to the Section 6056 reporting requirements.

Form 1094-C: required information

Each ALE must file a Section 6056 transmittal form (Form 1094-C) with its Forms 1095-C filed by the ALE. An ALE can file more than one Form 1094-C if groups of Forms 1095-C are filed together. However, there must be only one Section 6056 Authoritative Transmittal (Form 1094-C) reporting aggregate employer-level data for all full-time employees of the ALE.

The following information must be included on the Form 1094-C. All information must be completed by all ALEs, unless noted otherwise.

Part

Line

Required Information

More Details

I

1

Employer’s name

 

2

Employer’s nine-digit EIN, including the dash

 

3—6

Employer’s complete address (including room or suite no., if applicable)

 

7 & 8

Name and telephone number of the employer’s contact person who is responsible for answering any questions

 

9

DGE’s name

Lines 9-18 only completed by a Designated Government Entity (DGE) filing on behalf of an employer

10

DGE’s nine-digit EIN, including the dash

11—14

DGE’s complete address (including room or suite no., if applicable)

15 & 16

Name and telephone number of the DGE’s contact person who is responsible for answering any questions related to the Form 1094-C

17

Reserved for future use

18

Total number of Forms 1095-C submitted with this Form 1094-C transmittal

II

19

Whether this Form 1094-C is the Authoritative Transmittal (check the box if yes)

Complete Part II only on the Authoritative Transmittal

20

Total number of Forms 1095-C that will be filed by and/or on behalf of the employer

21

Whether the employer was a member of an Aggregated ALE Group during any month of the calendar year

22

Whether the employer meets the eligibility requirements and is using one of the Alternative Methods of Reporting and/or one of the forms of Transition Relief indicated

  • Whether the employer is eligible for and using the Qualifying Offer Method for one or more full-time employees (check Box A)
  • Whether the employer is eligible for and using the Qualifying Offer Method Transition Relief for the 2015 calendar year for one or more full-time employees (check Box B)
  • Whether the employer is eligible for Section 4980H Transition Relief based on its number of full-time employees (check Box C)
  • Whether the employer is eligible for and  using the 98% Offer Method (check Box D)

III

23—35, Column (a)

Whether the employer offered minimum essential coverage (MEC) under an eligible employer-sponsored plan to substantially all of its full-time employees and their dependents for the entire calendar year

 

23—35, Column (b)

Number of full-time employees for each month (do not count any employee in a Limited Non-Assessment Period)

ALEs eligible for the 98% Offer Method do not complete this column

23—35, Column (c)

Total number of employees (including full-time employees, non-full-time employees and employees in a Limited Non-Assessment Period) for each calendar month

 

23—35, Column (d)

The months for which the employer was an Aggregated ALE Group member

Only Aggregated ALE Group Members complete this column

23—35, Column (e)

The Section 4980H Transition Relief Based on Number of Full-time Employees the employer is eligible for (if any)

 

IV

36—65

Name(s) and EIN(s) of up to 30 of the other Aggregated ALE Group members, in descending order based on number of full-time employees

Only Aggregated ALE Group Members complete this column

 Wellness Program Waiver

 

Topics: Compliance

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