As the 2016 filing season gets underway, many individuals will be receiving new information returns from their employers and/or health insurance providers. The information returns reflect new reporting requirements put in place by the Affordable Care Act. Some taxpayers will need to wait to file their returns until they receive their information returns, but most taxpayers will not.

Background

The ACA generally requires certain employers, insurance providers and the Health Insurance Marketplaces to provide statements to covered individuals about their health insurance coverage. Under the ACA, all individuals must carry minimum essential health insurance coverage or make a shared responsibility payment, unless exempt. Individuals who obtain coverage through the Health Insurance Marketplace may qualify for a special tax credit, the Code Sec. 36B credit, to help offset the cost of coverage.

Forms

The IRS has developed new forms for ACA reporting

• Form 1095-A, Health Insurance Marketplace Statement, the Health Insurance Marketplaces provide Form 1095-A to individuals enrolled in coverage, with information about the coverage, who was covered, and when.
• Form 1095-B, Health Coverage, health insurance providers (for example, health insurance companies) send this form to individuals they cover, with information about who was covered and when.
• Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, Certain employers send this form to certain employees, with information about what coverage the employer offered. Generally these are “applicable large employers.”

This is the second year that the Health Insurance Marketplaces have provided Forms 1095-A to enrollees. However, this is the first year that health insurance providers and certain employers have furnished Forms 1095-B and 1095-C to covered individuals.

Deadlines

Health Insurance Marketplaces must provide enrollees with Form 1095-A by February 1, 2016. This year, the IRS has given health insurance providers and certain employers more time to furnish Forms 1095-B and 1095-C to covered individuals. The deadline to provide Forms 1095-B and 1095-C is March 31, 2016. Forms 1095-A, 1095-B and 1095-C will be mailed to recipients or provided electronically if the recipient has agreed to electronic delivery. Health insurance providers and certain employers also must file information returns with the IRS (Forms 1094-B and 1094-C) but those forms have different deadlines.

Returns

The IRS has instructed taxpayers who have coverage through the Health Insurance Marketplaces to wait to file their 2015 tax return until they receive Form 1095-A. Many enrollees in Marketplace coverage have received advance payments of the Code Sec. 36B credit and will need to reconcile the advance payments when they file their 2015 tax returns. These individuals will use the information on Form 1095-A to complete a separate form (Form 8962, Premium Tax Credit). Form 1095-A is not attached to a taxpayer’s return but retained for his or her records. As always, our office is here to provide assistance.

Individuals with employer-provided health insurance and other qualifying minimum essential health care coverage do not need to wait to file their 2015 tax return until they receive Forms 1095-B or 1095-C, the IRS has instructed. While the information on Forms 1095-B and 1095-C may assist in preparation of a tax return, they are not required, the IRS explained. Individuals may use other forms of documentation, in lieu of the information on Forms 1095-B and 1095-C, to show insurance coverage, such as insurance cards or payroll statements reflecting health insurance deductions, the IRS further explained. Like Form 1095-A, Forms 1095-B and 1095-C are not attached to the taxpayer’s return but are retained for his or her records.

If you have any questions about Forms 1095-A, 1095-B or 1095-C and the information they report, please contact our office.