Final 2015 ACA Tax Reporting Forms and Instructions Released

The Internal Revenue Service (IRS) has released the final versions of the 2015 Affordable Care Act (ACA) tax reporting forms and instructions:

No major revisions; helpful COBRA changes
While the final forms and instructions didn’t contain major revisions, there were changes and clarifications to COBRA coverage reporting that cooperatives will find helpful. When an employee terminates employment, an offer of COBRA coverage should not be reported as an offer of coverage in all circumstances. This is a change from prior IRS guidance that suggested that an offer of COBRA coverage should be reported as an offer of coverage if the employee enrolled in COBRA. The final 1094-C/1095-C instructions now direct those filling out Form 1095-C to:

Enter code 1H (no offer of coverage) on line 14 for a terminated employee, even if COBRA coverage is offered to that employee
Enter code 2A (employee not employed during the month) on line 16 for a former employee who elects COBRA coverage, rather than code 2C (employee enrolled in coverage offered)

Note: The IRS also released Notice 2015-68, which indicated that additional regulations will be forthcoming on Section 6055, individual mandate, or minimum essential coverage, reporting.

More help
Seth Perretta and Malcolm Slee of Groom Law Group will review the final forms and instructions for all member co-ops during the webinar at 2 pm ET on September 28. We also will provide more information on ACA tax reporting for 2015 as we review the final forms and instructions, as well other forthcoming guidance.

If you have more questions about ACA tax reporting, consult your co-op’s tax advisor.

This article is NRECA’s interpretation of IRS and ACA tax guidelines, and is not intended to constitute legal or tax advice. Co-ops and individuals should seek confirmation of the information in this article from their legal or tax advisors.