Compliance Updates: IRS Reporting, Federal Poverty Level, Medicare Part D Notification

1) Final 2014 Instructions and Forms 1094-C and 1095-C. The Internal Revenue Service released final forms and instructions for reporting on the individual mandate (Code Sec. 6055) and the employer mandate (Code Sec. 6056). While these final forms reference calendar year 2014, reporting for 2014 is not required. Employers will be subject to these reporting requirements for 2015 with filings due in early 2016. We expect revised forms reflecting the year 2015 to be issued in the future. These finalized forms provide us with better insight into the information that employers must collect and track during 2015 in order to comply with this reporting requirement.

2) 2015 Federal Poverty Level (FPL) Guidelines Announced. The Department of Health and Human Services released FPL charts for 2015. Notably, the threshold for the Federal Poverty Level Safe Harbor for purposes of affordability under the employer mandate rules increased to $93.18.

3) Employees Self-Certify Regarding Health Coverage in 2014. For calendar year 2014, individuals must report minimum essential coverage for each month of the calendar year on their annual tax return. Notably, for 2014, employers and carriers are not required to provide covered employees information regarding their health insurance coverage. Beginning calendar year 2015, however, employer and carriers will be responsible for issuing certain information to covered employees regarding health insurance coverage (see Final 2014 Instructions and Forms 1094-C and 1095-C, above).

4) Medicare Part D – CMS Notification Reminder. Employers sponsoring a group health plan need to report information on the creditable status of the plan’s prescription drug coverage to the Centers for Medicare and Medicaid Services (CMS). In order to provide this information, employers must access CMS’s online reporting system at: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html.

As a reminder, notice must be provided by the following deadlines:
– Within 60 days after the beginning date of the plan year;
– Within 30 days after the termination of the prescription drug plan; and
– Within 30 days after any change in the creditable coverage status.

An employer with a calendar year plan (January 1 – December 31, 2015) must complete this reporting no later than March 1, 2015.

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